Medway Local Plan (Regulation 18, 2024)

Southern Water supports all requirements which seek to ensure that surface water is appropriately managed, as close to source as possible. We therefore strongly support the content on “multi-functional green infrastructure” within policy S1. However, we would also like to see this policy go further and make suggestions for additional policy wording below.
Southern Water also supports the policy intention to minimise the use of natural resources, and we would welcome a reference to policy DM6 and the water efficiency standard referred to therein (that we submit a separate representation on in our response to this consultation).
Requested changes:
Effective Spatial Planning and Placemaking:
• 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.
Adaptation to climate change:
• Reducing water consumption using water re-use measures including rainwater harvesting, surface water harvesting and/or grey water recycling systems. Personal water consumption per day for new build should not exceed the Building Regulations recommended standard for water efficiency in water stressed regions.
Further explanation and justification:
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.
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. This is in line with paragraph 167(c) of the National Planning Policy Framework (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)
Southern Water is working across our region to remove surface water from our networks in key areas. Even as we deliver this work, development continues to increase surface water run-off. To be resilient to the evolving impacts of climate change we must plan to ensure that rainwater is separated from wastewater in the design and construction of our communities. For more information on our work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force
During heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. When these fill up, storm overflows release excess water through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, resulting in increased releases from storm overflows. 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’.
In terms of community resilience to the impacts of climate change into the future, better rainwater management through SuDS is the preferred approach. Retrofitting sustainable drainage solutions can be challenging. By showing the way with new development we can reduce the implementation costs of these measures whilst securing truly sustainable development.

Southern Water strongly supports Policy S5 and the inclusion of “multi-functional green infrastructure” wording throughout, as explained further below.
Further explanation and justification:
Southern Water supports all 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.
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. This is in line with paragraph 167(c) of the National Planning Policy Framework (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)
Southern Water is working across our region to remove surface water from our networks in key areas. Even as we deliver this work, development continues to increase surface water run-off. To be resilient to the evolving impacts of climate change we must plan to ensure that rainwater is separated from wastewater in the design and construction of our communities. For more information on our work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force
During heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. When these fill up, storm overflows release excess water through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, resulting in increased releases from storm overflows. 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’.
In terms of community resilience to the impacts of climate change into the future, better rainwater management through SuDS is the preferred approach. Retrofit of sustainable drainage solutions can be challenging but is also exemplary of good practice, and can be particularly necessary in areas of urban creep.

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 strongly support the inclusion of sustainable urban drainage solutions within this policy. However, we suggest some additional wording to help ensure this policy is effective in delivering appropriate surface water management.
Requested additions:
We note the following wording in this policy, and suggest additional wording for your consideration here:
• The proposal works with the topography of the site and the inventive incorporation / use / interpretation of existing natural features. 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.

Further explanation and justification:
Southern Water supports all policy requirements which seek to ensure that surface water is appropriately managed, as close to source as possible and has made representations across related policy. We also need to ensure that design of developments will not mean that existing surface water drainage routes are not impeded to result in flooding elsewhere. This is in line with paragraph 167(c) of the National Planning Policy Framework (NPPF) (2023) that requires:
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)
Southern Water is working across our region to remove surface water from our networks in key areas. Even as we deliver this work, development continues to increase surface water run-off. To be resilient to the evolving impacts of climate change we must plan to ensure that rainwater is separated from wastewater in the design and construction of our communities. For more information on our work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force
In terms of community resilience to the impacts of climate change into the future, better rainwater management through SuDS is the preferred approach. Retrofitting sustainable drainage solutions can be challenging. By showing the way with new development we can reduce the implementation costs of these measures whilst securing truly sustainable development.

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 at design stage in order to ensure that actual use remains efficient throughout the lifetime of the development. We therefore suggest the following changes for your consideration, explaining our reasoning below:
Requested DM6 changes:
All new dwellings must be designed to achieve the Optional Technical Housing Standard for water efficiency described in Building Regulation G2. Design must also consider potential for future tightening of this standard by targeting use at no more than 100 litres per person per day.
Further explanation and justification:
We support the inclusion of the Building Regulations optional standard for water efficiency in this policy. However, although current Building Regulations indicate this is appropriate to the ‘serious water stress’1 status of the South East, the Government plans to tighten2 this Building Regulations standard. 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. 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.
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
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 meet the highest standards of water efficiency possible at the time.

Southern Water supports all policy requirements which seek to ensure that surface water is appropriately managed, as close to source as possible. As acknowledged in the plan, community resilience to the impacts of climate change is essential. We therefore request wording is added to strengthen the effectiveness of this policy S15, as explained further below:

Requested changes:
• Enhancements and provision of multi-functional green infrastructure, public realm incorporating sustainable urban drainage features and improved access to blue infrastructure where possible.
Further explanation and justification:
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) that requires:
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)
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.
Southern Water is working across our region to remove surface water from our networks in key areas. Even as we deliver this work, development continues to increase surface water run-off. To be resilient to the evolving impacts of climate change we must plan to ensure that rainwater is separated from wastewater in the design and construction of our communities. For more information on our work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force
During heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. When these fill up, storm overflows release excess water through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, resulting in increased releases from storm overflows. 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’.
Stronger integration of sustainable drainage solutions within policy should ensure SuDS are incorporated into new development and public places, whilst also securing truly sustainable development. Please see our policy statement on Sustainable Development here:
https://www.southernwater.co.uk/media/ny0nb3qu/our-policy-statement-on-sustainable-development-a4.pdf

Southern Water would support the inclusion of permeable paving and SuDS in this policy. We therefore suggest the addition of the following wording to this policy:

Parking areas should incorporate appropriate sustainable urban drainage measures and developers ensure their design does not increase flood risk locally.

Further explanation and justification:
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) that requires:
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)
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.
Southern Water is working across our region to remove surface water from our networks in key areas. Even as we deliver this work, development continues to increase surface water run-off. To be resilient to the evolving impacts of climate change we must plan to ensure that rainwater is separated from wastewater in the design and construction of our communities. For more information on our work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force
During heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. When these fill up, storm overflows release excess water through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, resulting in increased releases from storm overflows. 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’.
Stronger integration of sustainable drainage solutions within policy should ensure SuDS are incorporated into new development and public places, whilst also securing truly sustainable development. Please see our policy statement on Sustainable Development here:
https://www.southernwater.co.uk/media/ny0nb3qu/our-policy-statement-on-sustainable-development-a4.pdf

Southern Water strongly supports the consideration of multi-functional green infrastructure within this policy, in particular the wording:
Design of new open space
Proposals for development which include provision of new on-site open space must ensure that new open spaces meet these quality standards below:
(a) Be designed as part of the green infrastructure network, contributing to local landscape character, connecting with local routes and green corridors for people and wildlife as well as providing multi-functional benefits such as addressing surface water management priorities without compromising access.
Southern Water supports the inclusion of permeable paving in the policy. Southern Water supports all policy requirements which seek to ensure that surface water is appropriately managed, as close to source as possible. This aligns with our own 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
Stronger integration of sustainable drainage solutions within policy should ensure SuDS are incorporated into new development and public places, whilst also securing truly sustainable development. Please see our policy statement on Sustainable Development here:
https://www.southernwater.co.uk/media/ny0nb3qu/our-policy-statement-on-sustainable-development-a4.pdfhttps://www.southernwater.co.uk/media/7459/stormoverflows_faq.pdf

Southern Water may have to provide additional water or wastewater infrastructure to serve new and existing customers or meet stricter environmental standards. It is likely that there would be limited options with regard to location, as the infrastructure would need to connect into existing networks. Planning policies should therefore support proposals that come forward in order to deliver or maintain necessary infrastructure. We therefore request that the following wording is added to this policy, as explained further below:
New and improved utility infrastructure will be encouraged and supported in order to meet the identified needs of the community subject to other policies in the plan.
Further explanation and justification:
We could find no policy wording that specifically supported the general provision of new or improved utilities infrastructure. The NPPF (2023) paragraph 7 establishes that ‘supporting infrastructure in a sustainable manner’ is key to achieving sustainable development, and although this is acknowledged in relation to developments, broader provision by utilities providers is also sometimes necessary. Also the National Planning Practice Guidance states that ‘Adequate water and wastewater infrastructure is needed to support sustainable development’.

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.