Medway Local Plan (Regulation 18, 2024)

We strongly support the measures included within the draft Local Plan for the mitigation of climate change. We would support their broad adoption across policy for all types of site, for example across policies T10 and T11 to help reduce the risk of negative environmental impacts arising from new development. Water efficiency: The South East region incorporates many environmentally sensitive areas and is classified as an area of ‘serious water stress’. Significant challenges and environmental improvements need to be addressed, while at the same time enabling some of the highest rates of growth in the country. This together with the increasing impacts of climate change expected over time mean we need to significantly reduce our water use. Tackling water scarcity requires a multi-faceted approach and there is an opportunity for the planning system to play a part by ensuring policy requires new development to meet the highest standards of water efficiency possible at the time. For water efficiency in the design of new homes, the current Building Regulations standard1 for water stressed areas is to design for a maximum use of 110 litres of water per person per day. We support the inclusion of the Building Regulations optional standard for water efficiency in policy DM6 of the plan. However, targeting a more efficient standard makes sense in design, in order to ensure that actual use conserves water resources. We would therefore ideally like to see tighter water efficiency targets in the design of new homes. This is in line with Southern Water’s ‘Save a Little Water’ programme to consume no more than 100 litres per person per day across our region. Also, the Government plans to tighten2 the Building Regulations standard. 1 Water_stressed_areas___final_classification_2021.odt (live.com) 2 https://database.waterwise.org.uk/knowledge-base/building-regulations-water-efficiency-review/ https://www.gov.uk/government/news/ambitious-roadmap-for-a-cleaner-greener-country High standards of water efficiency in new developments also equate to greater long-term sustainability, future-proofing our communities to the impacts of climate change. Surface Water management and sustainable drainage: Southern Water supports all policy requirements which seek to ensure that surface water is appropriately managed, as close to source as possible. We need planning policy to consider carefully the measures called for in response to the climate crisis, and ensure sustainable development is central to the local planning framework for planning applications coming forward. This is also in line with the requirements of paragraph 167(c) of the NPPF (2023). 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. Please see our policy on Sustainable Development here: https://www.southernwater.co.uk/media/ny0nb3qu/our-policy-statement-on-sustainable-development-a4.pdf Southern Water is strongly supportive of sustainable urban drainage solutions (SuDS) as these will be essential to establishing community resilience to the impacts of climate change into the future. Whilst we appreciate there may be a need for some flexibility, Southern Water considers SuDS essential for all development to ensure mitigation of climate change impacts into the future and ask that this be reflected throughout the Local Plan. Currently paragraph 4.8.18 emphasises the need for SuDS in relation to sewer capacity, where this emphasis could simply be placed on the resilience of communities into the future - as suggested in our proposed changes 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: https://www.southernwater.co.uk/media/l23dbon0/surface-water-management-policy-120724.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. *https://www.southernwater.co.uk/media/ooubtggs/suds-in-spz-guidance.pdf 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 this additional guidance (above link) that Southern Water has produced for sustainable urban drainage solutions within source protection zones? We also ask that 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. We have made separate representations making this request. Whilst we appreciate that not all water companies will 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. 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) 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.

No answer given

Although as a water and wastewater service provider, we cannot comment on the Council’s proposal to plan for non-inert waste to be managed at sites outside of Medway. We note that paragraph 12.8.1 describes the present quantity of non-inert waste and capacity as follows: While non-inert landfill capacity across the South East is declining, the quantity of waste that needs to be disposed of in this way is also declining and this is expected to continue in light of Government initiatives. However, as sewage sludge is one form of non-inert waste, we provide some additional information from the wastewater utility sector for your consideration. Although sewage sludge represents only a proportion of the non-inert waste this paragraph discusses, the risk of a decline in available landbank for biosolids is a concern to the sector*. Should an alternative disposal route be required for sewage sludge in the short-term, this could have an impact on the ‘declining trends‘ referred to in paragraph 12.8.1 of the draft Plan. *For further information please see the following: • https://www.waterindustryjournal.co.uk/sludge-management-biosolids-recycling - Biosolids (or treated sewage sludges) typically have two markets – land application and incineration. Application to land, in compliance with the regulatory and good practice requirements, is still considered the best practicable environmental option in most cases. Alongside Spain and France, the UK recycles the majority of biosolids to these markets, with an emphasis on agricultural land. • https://utilityweek.co.uk/fear-of-forever-chemicals-could-put-paid-to-biosolids/ - Today 87% of the UK’s treated sewerage sludge is recycled as an agricultural fertiliser and soil improver – the only current disposal outlet alongside land restoration. But wastewater company business plans for PR24 reveal the level of concern over the sustainability of this disposal route from as early as the next asset management period (AMP8). This is due to a raft of regulatory changes looming on the horizon, each with the ability to severely reduce the landbank available for disposal. • https://www.water.org.uk/waste-water/extracting-resources-sewage - We are currently looking at what other opportunities there are to use sewage sludge to ensure that the sector has a sustainable future sludge treatment strategy. Other markets that have the potential to use sewage sludge include construction (as the filler for bricks) and plastics.