Written evidence from Thames Water (ARSS
We recognise the Government's intention to abolish
regional spatial strategies as part of a broader policy of decentralisation,
and trust that the advantages of the old system for planned infrastructure
delivery can be retained under forthcoming arrangements.
Water and sewerage companies require as much certainty
as possible about housing growth figures in order to plan ahead
and provide adequate water and drainage infrastructure when needed.
We are concerned that the abolition of regional spatial
strategies (RSSs) reduces this certainty, which could lead to
negative environmental impacts and poor outcomes for customers.
RSSs provided the strategic policy framework on large-scale
water and sewerage infrastructure of regional importance. Their
abolition makes it unclear who will decide on strategic policy
matters in future.
It is vital that strategic water and wastewater matters
are considered at the appropriate level. Planning policy must
then support delivery of required infrastructure at the right
We welcome the opportunity to submit evidence to
the Committee to assist with its inquiry on the abolition of regional
spatial strategies. This submission sets out our views on the
We trust this submission will help inform the Committee's
analysis and we would, of course, be happy to discuss our views
in more detail.
The implications of the abolition of regional
house building targets for levels of housing development
1. Thames Water is the UK's largest water and
wastewater services company. We serve 8.7 million water customers
and 13.8 million wastewater customers across the London and Thames
Valley area, from Kent and Essex in the east to the edge of Gloucestershire
in the west. This area is governed by more than 100 local authorities
and falls into four regions:
London (unaffected by the abolition of RSSs)
the South East;
the South West; and
the East of England.
2. Every new commercial or housing development
in our area is entitled to connect to our local clean water and
drainage networks, so we need a clear view of expected levels
of housing growth in order to deliver the infrastructure needed
to serve our customers. Regional spatial strategies (RSSs) provided
this clarity, because their housing targets told us where growth
would happen and how fast it would come. Accordingly, we produced
our £4.9 billion investment programme for 2010-15 in line
with RSS housing growth figures to minimise the risks of unfunded
costs and inadequate infrastructure. Failure to provide appropriate
infrastructure can have serious consequences for customers and
the environment, including sewer flooding or localised water shortages.
A lack of clarity could lead to investment in areas that do not
experience growth, which would waste money and resources.
3. Even before the advent of RSSs, there were
still regional plans such as Regional Planning Guidance note 9
(RPG9) which provided housing figures. These plans were not part
of the statutory development plan and were therefore of a lesser
status but still provided us with useful projections on housing
levels. At county level, these housing figures were also included
in structure plans, which no longer form part of the development
plan. The revocation of regional spatial strategies therefore
represents a significant departure from previous approaches.
4. Following the revocation of regional spatial
strategies in July 2010, we wrote to all local authorities within
our area (outside London) to ask whether they would review or
retain their RSS targets.
5. Out of 46 local authorities who responded,
only 21 had actually taken a decision. It is clear that many authorities'
housing strategies will be delayed, sometimes by around six to
seven months. We are concerned that this ongoing uncertainty around
future housing levels makes it difficult for us to plan for growth
and avoid poor outcomes for customers.
6. Furthermore, we believe that the revocation
of RSSs has removed an important strategic level of planning policy.
We recognise the Government's intention to abolish regional spatial
strategies as part of a broader policy of decentralisation, and
hope that the advantages of the old system can be retained under
forthcoming arrangements. Our region requires large-scale investment
in infrastructure to address urgent environmental needs, such
as river water quality or increasing demand for water. The RSSs
contained detailed policies on these issues and were essential
guides to local authorities when deciding on planning applications.
7. For example, the South East Plan (May 2009)
provides for new water and wastewater infrastructure to address
population growth and rising environmental standards.
The Plan identified new water resource schemes in the policy,
which required local authorities to work extensively with the
water companies and the Environment Agency to deliver these schemes.
These schemes were identified on the basis of water companies'
Water Resource Management Plans or through regional modelling
of water supply-demand balance while the Plan was being prepared.
The Plan also required local authorities to allocate and safeguard
sites that could host the necessary infrastructure. Even where
schemes were not certain to progress, authorities were told to
safeguard the sites nonetheless so as not to limit any options
in future. Revoking the RSSs has removed this strategic perspective
without identifying any replacement.
8. The absence of the strategic framework that
RSSs provided leaves a gap in planning policy between local and
national levels. This gap is unlikely to be filled in the short
to medium term and could make it harder for us to provide strategic
infrastructure when it is most needed. This is particularly important
because some local authorities have not covered water and drainage
infrastructure in local development frameworks on the grounds
that the issues were already covered in the RSS. In other words,
the need for strategic investment in water resources is no longer
recognised at either regional or local level.
The implications for cooperation and data-sharing
between local planning authorities
9. We manage our water resources on the basis
of river basins, not administrative boundaries, so strategic resource
management is better done at a regional level to reflect the water
resource zones that companies use. For example, the South East
Plan, which examined the relationship between our plans and regional
housing growth projections, recognised that the proposed Upper
Thames Reservoir in Oxfordshire would act as a strategic regional
resource for customers in the Swindon-Oxfordshire and London water
Our preferred long-term option is to build a new reservoir in
Oxfordshire by 2026.
10. It is essential to take a strategic approach
to planning such a key resource, given the reservoir would be
located in one region while providing water to three regions (the
South East, London and the South West) and more than 20 different
11. It is unclear how this gap in regional planning
will be filled and the relevant data captured, in particular on
issues that affect many local authorities. There is potentially
an increased risk of inconsistency between local authorities that
may lead to confusion, shortfalls or unfunded obligations for
companies. To avoid this risk, it is critical that water companies
and Environment Agency are directly involved in all water and
wastewater matters previously covered by the RSS.
12. More generally, mechanisms should be put
in place to allow Local Enterprise Partnerships or other strategic
bodies to assume a coordination role in regional planning. This
could also be achieved through groups of local authorities co-ordinating
together. In the absence of a formal regional framework such voluntary
groupings, involving authorities with common issues, could provide
a route for the sort of co-operative approach that is needed.
By jointly considering issues such as housing and infrastructure
provision this would help ensure a coherent, co-ordinated approach,
promoting sustainable economic development while providing the
necessary clarity around the need for new infrastructure. The
members of such groupings would need to be able to adopt binding
housing targets to ensure a co-operative approach was maintained.
13. While their impact is limited to the water
sector only, we believe that Water Cycle Studies (WCSs) could
potentially help, if undertaken widely. Many local authorities
have undertaken WCSs to determine what sustainable water and wastewater
infrastructure is required, and where and when it is needed. A
WCS considers environmental capacity and technological constraints,
and involves other stakeholders in the process including water
companies and the Environment Agency. We believe that WCSs should
be carried out by all local authorities and they clearly must
reflect the particular environmental and growth circumstances
of that area. Where stakeholders raise a strategic issue, local
authorities should work together to consider the issues on a catchment-wide
basis. Where there are issues of a more strategic, regional nature,
there may be a role for county councils and unitary authorities?
to work together, drawing upon the WCSs, Water Resource Management
Plans and Surface Water Management Plans. Equally, there may be
a role for the Environment Agency in coordinating the process
of determining which infrastructure is required, with input from
water companies and local authorities.
14. Ultimately, whether or not WCSs are used
as a vehicle, it is vital that strategic water and wastewater
matters are considered at the appropriate level. Planning policy
must then support delivery of required infrastructure at the right
15. We believe that the evidence base prepared
by the Regional Local Authority Leaders' Boards is a valuable
resource that provides a basis on which individual planning authorities
could seek to establish their own housing targets. This data should
be made publicly available in the interests of transparency and
accountability, possibly through an online database. Once this
data is published, local authorities should be held accountable
for keeping the information up to date.
177 See policies NRM, NRM2 and NRM3 of the South East
Plan, May 2009. Back
See policy NRM3 of the South East Plan. Back