Written evidence from Southern Water Services
(SWS) (ARSS 108)
Government needs a planning system that encourages,
not defers, private sector investment in water and sewerage infrastructure,
which typically spans more than one local authority boundary.
Regional spatial strategies have usefully informed
Southern Water's investment plans on the likely level of new development
in the region and the location of strategic development sites.
They have also provided planning policy support for the delivery
of major investment.
In contrast, Local Development Frameworks have failed
to provide the planning certainty required by the private sector
to plan and deliver infrastructure investment.
The proposed "duty to co-operate" is an
inadequate substitute for regional spatial strategies. There remains
a need for strategic regional plans that have been tested via
public examination.
Taking over matters formally covered by regional
spatial strategies may be a role that could be undertaken by Local
Enterprise Partnerships.
An example is provided of the planning support required
for delivery of major infrastructure investment. The Committee
is invited to use it to test the effectiveness of future proposals.
Southern Water Services (SWS) provides water services
to about two million customers and sewerage services to over four
million customers in Kent, Sussex, Hampshire and the Isle of Wight.
SWS is a major investor in water and sewerage infrastructure in
the south east and welcomes the opportunity to comment on the
abolition of regional spatial strategies.
Government needs a planning system that encourages,
not defers, private sector investment in water and sewerage infrastructure.
Water and sewerage infrastructure has boundaries that do not coincide
with those of local authorities. Major infrastructure often serves
either a group of local authorities or is located in a strategic
location within a region that serves all of them. In some cases
infrastructure required to serve communities in one local authority
has to be located in another local authority because of environmental
or planning constraints. Regional spatial strategies that have
been tested via public examination provide the private sector
with the planning policy necessary to support delivery of major
investment in infrastructure that extends beyond neighbourhood
or district boundaries. Abolition of the South East Plan has left
a strategic planning gap.
SWS is neutral on the issue of the abolition of regional
house building targets for levels of housing development. However,
the regional house building targets have been useful in informing
SWS' long term investment plans on the likely level of new development
in the region and the location of strategic development sites.
Although future housing targets are not an issue on which SWS
can comment, planning certainty with respect to the location,
scope and timing of development is essential for infrastructure
investment. Adopted Local Development Frameworks (LDFs) should
provide this certainty by informing the water industry what, when
and where additional infrastructure is needed. However, the LDF
process has failed to meet his need as very few local authorities
have progressed their plans to adoption.
The proposed duty to co-operate is considered to
be an inadequate substitute for regional spatial strategies. An
overarching body is needed to take responsibility for strategic
planning at regional level and set out investment priorities and
solutions that extend beyond individual local authority boundaries.
Regional Planning Guidance and county council Structure Plans
provided policy guidance before the regional spatial strategies
were developed. Whilst SWS is not advocating a return to either
of these models, planning policy at this level is still required.
Local Enterprise Partnerships may have a role to play in this
process, which SWS would support if the strategic or regional
plans were tested via public examination.
Water resources are planned regionally through statutory
Water Resources Management Plans (WRMPs). A regional approach
is necessary because the south east is designated a water stressed
area and water resources are not available locally to supply major
centres of population. Balancing water demand with supply relies
on the coordinated use of strategic resources across the south
east and the transfer of water from areas of surplus to areas
of deficit. The South East Plan set out the long term strategy
for housing development across the region and included planning
policies which supported the development of additional strategic
water resources. House building targets, broken down by local
authority, usefully informed the WRMP because they had been tested
via examination in public. The abolition of the South East Plan
and the failure of the majority local authorities in SWS' area
to progress LDFs to adoption presents a major gap in planning
policy across the region.
The following example is provided to illustrate the
planning policy support Southern Water requires to deliver major
investment in additional water infrastructure.
Bewl Reservoir, on the county border of East Sussex
and Kent, is a major regional water resource that is shared by
water companies in the south east. Water from the reservoir is
used to supply drinking water throughout Kent and East Sussex.
The South East Plan recognised the need for development of new
strategic water resources in policy NRM3 and provided support
for their delivery. Abolition of the regional spatial strategy
leaves the decision on future water resource development to the
local authorities. Bewl Reservoir falls within three local authorities,
Rother DC, Tunbridge Wells BC and Wealden DC. The scale of increased
demand for water locally in these three local authorities will
never trigger a requirement for investment to enlarge the reservoir.
However, increased demand from development further afield in Thameside,
Medway and Thanet will certainly drive the need for additional
resources and reservoir enlargement at some point in the future.
The reservoir enlargement will require planning permission from
the three local planning authorities.
The Communities and Local Government Committee are
invited to use the above example to consider whether future planning
policy proposals would support the three local authorities facilitating
the delivery of a major water resources investment scheme within
their areas that is required to meet the needs of development
that falls outside their areas.
September 2010
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