Rainwater harvesting should a requirement for all new planning applications to improve water scarcity resilience.

There is already frequent flooding in the Luton area, suggesting that there has already been too much building going on.

We need to make more use of recycling waste water for watering green spaces or flushing toilets. Some toilets even have sinks on top of the cisterns so that you can wash your hands and the water gets stored in the cisterns after use and then used to flush. Any new developments must include reduced water useage like dual flush toilets or automatic taps so that they only come on when you wash your hands so you can’t leave the tap running.

Need to consider the longer term. Developers can incorporate water efficiencies, etc but people may swap these out and add to hardstanding with patios, etc. Rules around properties and enforcement are needed to ensure good measures are not later replaced with bad.
Run off should be captured and/or kept separate from waste. Education of public. Are there measures around houseboats and waste?

Lots of verbose words. But I agree.

I know that Southern water have made, previous, objections re development and the water table. Given that we do have flood issues on Hempstead Road, how will you ensure that this will not become a more generalised problem?

I live a short distance from the River Medway. I have always been under the impression that land adjacent to river along Lower Rainham Road was considered “to be on a flood plain”. I am therefore surprised to see plots of land for sale with planning permission along this stretch of road.

We have had several waste sites made by Biffa over the years very near to Allhallows, we have also suffered pollution in the past from many industries at Grain. The air quality has been very bad on some days. We also live in fear of flooding should the Thames Barrier be used to save London from flooding. Over this past year we have been alerted to high tides as a warning of possible flooding

Southern Water has some requested changes to statements on pages 48 and 50 please (in addition to feedback on the policy that follows on below):
Paragraph 4.8.12:
Southern Water has developed the DWMP in consultation with Local Authorities, and fed outcomes into the AMP8 business plan proposals, for which the final determination is due from Ofwat in December 2024. We therefore suggest the following changes to this paragraph 4.8.12:
Southern Water is the primary provider for wastewater disposal within Medway and are currently developeding Drainage and Wastewater Management Plans in consultation with regional stakeholders across their catchments, including Medway. Drainage and Wastewater Management Plans are long-term plans that will provide an opportunity to improve water quality and drainage systems and will address pollution and flooding for the benefit of communities and the environment. These long-term plans take into account projected growth over the Local Plan period.
Paragraph 4.8.15:
We welcome the reference in paragraph 4.8.15 to Environment Agency guidance for the protection of groundwater quality, and ask if the Plan could also refer to the additional guidance that Southern Water has produced for sustainable urban drainage solutions within source protection zones here - https://www.southernwater.co.uk/media/ooubtggs/suds-in-spz-guidance.pdf
For effective and sustainable surface water management, 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 whilst mitigating the risk of rogue behaviours by requiring appropriate levels of treatment in SuDS designs only where the conditions warrant it. Southern Water has produced ‘SuDS in SPZ guidance’ to support developers and policy makers when considering SuDS design.
Paragraph 4.8.18:
Currently paragraph 4.8.18 emphasises the need for SuDS in relation to sewer capacity, where the emphasis could be more effective when placed on the resilience of communities into the future in the face of climate change, as suggested in the changes we propose below:
SuDs measures are of particular importance also for new developments within areas where there may be sewer capacity limitations. Increased take up of SuDs will improve resilience of Medway over the Local Plan period and beyond and contribute towards climate adaptation.
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.

DM1 Flood & Water Management
Southern Water strongly supports the inclusion of sustainable urban drainage within this policy. However, we would also like to see this policy go further and make suggestions for additional policy wording below.
Requested additions:
Sustainable Urban Drainage:
• Existing surface water flow routes and drainage features within the site should be identified and preserved wherever these contribute to sustainable drainage eg ditches, seasonally dry watercourses, historic ponds.
• To minimise the risk of sewer flooding and protect water quality, surface water will not be permitted to discharge to the foul or combined sewer network.
• For infiltration SuDS within source protection zones, as part of their planning application Developers should provide evidence of having consulted the statutory water company responsible for the SPZ, to confirm the proposed SuDS design is appropriate to this sensitive hydrogeological location.

Further explanation and justification:
Southern Water supports all policy requirements which seek to protect public drinking water supplies and ensure that surface water is appropriately managed, as close to source as possible. We also need to ensure that design of developments will not mean that rainwater continues to run off homes and surfaces so fast that it causes flooding.
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. We therefore strongly support the requirement to include SuDS within all development. This is also in line with the requirements of paragraph 167(c) of the 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)
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
Measures should support 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 (see our policy on SuDS in source protection zones below).
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
As both a water and wastewater company, Southern Water is a key stakeholder for sustainable drainage solutions (SuDS). SuDS include both infiltration and attenuation measures. Infiltration SuDS are not always appropriate within Source Protection Zones, further explanation is provided in our policy here - https://www.southernwater.co.uk/media/ooubtggs/suds-in-spz-guidance.pdf
The Environment Agency is the regulatory authority on protection of groundwater sources. Southern Water has developed additional guidance in consideration of potable water standards to help safeguard the water quality of SPZ through the responsible design of SuDS.
Whilst we appreciate that not all water companies might want to work in the same way, Southern Water needs planning policy wording to help ensure Developers consult Southern Water on their infiltration SuDS designs within SPZ. This will help to ensure infiltration SuDS designs remain as viable as possible per site, whilst being appropriate for their location.

--We rarely see any work being done on unclogging street drains and this becomes an embarrassing problem when there is a bit too much rain. Lack of maintenance is a false saving.

Affirm. One concern is how we can adapt existing areas of hardstanding in private dwellings to adapt surfaces to allow more permability and slower run off during periods of higher rainfall.

Binney rd floods. Ditches regularly overflow and need clearing out not being planted with aesthetically pleasing weeds by developers! The sewage pumping house is at full capacity and is often pumped out by big lorries which damage the lane even further. It often smells really bad. The current horse yard floods and cannot be accessed by vehicles and horse boxes cannot be moved It is also too wet for horses to graze.

Any development around here makes no sense, especially on a hill. Houses will be damaged on North Dane Way by any flooding. Just look at the ones at the bottom by the roundabout

Agree , doubt if Southern Water are to the task , very poor record so far under their watch.

We have yet to experience flooding the like of other counties but I think we are under prepared.
Medway Council should urge water companies to repair, maintain and increase supplies to areas in need and areas of future growth.
There are already areas which are not coping and the problems will only be exacerbated by the planned extra housing, combined with the climate changes which are already having an effect.

This policy could be simplified to state: "No development will be allowed on any natural Flood Plain. No new development will be allowed in any area which does not have waste water infrastructure capable of handling the existing development."

Dont build on flood zones

no housing should be built on flood plains , waste water in allhallows is not up to standard and the water pipes need replacing as they are always bursting

I strongly support this policy, in particular development that would harm the effectiveness of existing flood defences or prejudice their maintenance or management will not be permitted unless it can be suitably mitigated.

No comments

Building along the landscape next to North Dane Way will exacerbate flood risk to properties in Luton and Hale which have flooded several times in recent years.

I have concerns with water management. The Capstone area once had 5 ponds in and around Capstone Road & Sharsted Road. These ponds functioned to contain the excess water in this area. Since these ponds have gone (with the exception of that incorporated into the lake at Capstone Park) water gathers with any precipitation flooding these roads rendering them impassable. When changes have been made to the lie of the land at Gibraltar Farm my land has suffered water logging & despite noting this, no-one has taken it into account. I don't believe flooding has been given sufficient consideration.

Working with the water company’s give us a realistic timeline for wastewater and run off issues to reduce, keep the date in the public eye.

The planned development in Allhallows on a floodplain is troubling, especially as environmental conditions worsen each year. This should not proceed. Previously, Medway Council built homes on dairy fields near my house, also on a floodplain, and burst a water main in the process. This main has been leaking constantly, collapsing the road, yet the council deemed it acceptable. The area also suffers from frequent water mains leaks. Blocking essential ditches with plants has worsened flooding, showing a lack of proper planning. Building on a floodplain again would only exacerbate these issues and increase environmental damage.

I support this policy and I am extremely pleased to see that development that would harm the effectiveness of existing flood defences or prejudice their maintenance or management will not be permitted - unless it can be suitably mitigated.

It is important that flood risk work is completed prior to a Local Plan being adopted and not just on the planning application. If a site is going to be part of the LP then we must be confident it can be delivered. There is a danger otherwise that development will either not come forward at all, or will only come forward with government grants or with reduced, previously agreed, affordable housing contributions or S106 contributions.

What provisions would be put in place to ensure developments meet water and waste water infrastructure needs without tree or detriment to existing networks.

I have seen first hand new "infill" developments overwhelm sewerage systems. leading to people's houses flooding after having been there for many decades without an issue. ( this is surface water dranage in a hilly area) Perhaps some s106 monies can be placed into monitoring and preventing both this and the task of sustainable driveways. Too many people concrete over their driveways without permission and without drainage. The enforcement team need to be beefed up.

Agricultural land use and change requires scrutiny to avoid negative impacts from surface water run off and increased flood risk to local communities and property. Arable conversion to viniculture creates a major risk, land use management plans for businesses engaged in this significant change should be required to have a water management plan that mitigates negative impacts and risk and should be overseen by local authority and Environment Agency.

Use of pesticides and fertilizer should also be managed better and regulations policed to avoid nutrient run off and polluting groundwater. Local Authority should support citizen groups to aid this.

Medway/UK strongly need Climate action to lessen increasing flooding of low-lying built-up parts of the area.
Could the heading 'Sustainable Urban Drainage' be altered to 'Sustainable Drainage' since SuDS, if used for new development on the Peninsular, will in effect be in rural areas too? The use of SuDS as drainage in rural areas for access roads and carparks within SPZ1 groundwater protection zones, would also require a hydrogeological risk assessment. As might repetitive spraying of copper sulphate in vineyards.
I am unclear how longterm management and maintenance of SuDS happen should the company involved go into liquidation.