Agenda item

Southern Water are consulting on a Drainage and Wastewater Management Plan(DWMP) over the period 13 June to 5 September 2022. This DWMP document has been split into 5 papers, which cover the overall strategy and approach Southern Water intends to take over the next 25 years for the wastewater catchments they serve. Members are asked to consider and agree the proposed consultation response. [The proposed response will be circulated separately ahead of the meeting.]

[Councillor Lury was absent for the vote on this item.]

The Chair welcomed David Murphy, Senior Project Manager at Southern Water, to the meeting. Upon the invitation of the Chair, Mr Murphy gave a presentation to the Committee on Drainage and Wastewater Management Plans and Southern Water’s current public consultation (a copy of the presentation can be found on the meeting’s webpage). The Planning Policy Team Leader then presented the report which asked Members to consider and agree the proposed consultation response to Southern Water’s consultation on its Drainage and Wastewater Management Plan(DWMP). It was explained that the DWMP document had been split into 5 papers (Internal Sewer Flooding, Sewer Condition and Groundwater Pollution, Storm Overflows, Compliance and Pollution, and the Environment) which covered the overall strategy and approach Southern Water intended to take over the next 25 years for the wastewater catchments they served.

Members then took part in a full debate on the item where a number of points were raised including:

·       support for the management plan and the Officers’ response to the consultation

·       the need to very strongly support nature-based solutions

·       regret that the Local Plan update had been put on hold as it had climate change development management policies that would have enabled the Council to ask more of developers

·       the need for sustainable rainwater catchment solutions in an increasingly urban area in order to keep rainwater and wastewater drainages separate

·       concern that without the Local Plan update resumed, the District could see several more years of housing development without adjustment for this issue

·       Lidsey Treatment Works capacity and whether this would exceed the permit levels before 2025

·       Southern Water’s previous capital investment horizon having been 17 years, this having now increased to 25 years and both durations being long periods of time when compared with the rate of house building in the District

·       the issue of blockages to internal sewer flooding and, whilst still needing to educate customers to change habits, whether Southern Water was considering fitting interceptors at strategic points in the network to lessen the impact of these

·       following the Environment Agency’s recent report into Southern Water’s performance as ‘terrible across the board’ including a threefold increase in serious pollution incidents in the last year and ‘significant issues’ in the reporting of their water management plans to DEFRA, how anyone could have any confidence that any of Southern Water’s plans would happen

·       given Southern Water’s admission that water in Sussex was stressed, the extent to which water neutrality was considered at the housing development design stage but also what was being done about water neutrality now

·       the impact of any increase in permit levels by the Environment Agency and the resultant perceived increase in capacity on the Local Plan update, and in particular housing numbers and an increase in incidents of overflow

·       the need for some sort of enforcement to deal with blockages as the largest single reason for internal sewer flooding, either on manufacturers to use more suitable materials or by putting warnings on packaging to better educate consumers

·       where the most serious ingresses to the system were or were expected to be

·       agreement about the lack of education around what was flushable

·       rainwater having been identified very clearly in Southern Water’s presentation as the principal issue of overflows and therefore getting people to use less water not really making any difference to the issue of flooding

·       how Southern Water would stop rainwater from roads, paved areas and roofs going into the sewers

·       how sustainable drainage systems such as green roofs, permeable paving and wetlands would work in this area with very high groundwater levels

·       storage tanks as a solution to overflows, but questions over a lack of detail in how much bigger these would need to be in order to solve this issue and the levels of disruption the installation works might cause

·       concerns over the need for tankerage if the storage tanks were not big enough to hold the necessary quantities

·       the need for grey water systems and their installation in all new developments to be part of the Local Plan update when resumed

·       the importance of the tourist economy to the area and the impact of raw sewage discharges to Arun’s communities

·       the public perception of Southern Water not willing to change the area’s Victorian sewer systems originally designed for a significant smaller population

·       a lot of the work on nutrient neutrality taking place further upstream which meant that farm run-off and its resultant pollution were dealt with before they reached Arun and so the District still benefitted from current initiatives

·       rain gardens and other nature-based solutions and their ability to filter run-off water before it reached water courses

·       the need for the Committee to educate itself on the solutions available whilst at the same time working with the water companies

The Senior Project Manager from Southern Water provided Members with responses to points raised during the debate, including:

·       confirmation that action was already being undertaken at Lidsey Treatment Works on capacity, and in the current investment period of 2020-25 £15 million was being spent at Lidsey to increase capacity to provide headroom for growth up to 2035 and to increase the amount of flow that could be taken through to full treatment to avoid spilling to the environment in dry weather

·       long-term planning demonstrated that Southern Water was thinking ahead particularly regarding growth and climate change, and that the timescales allowed for the infrastructure to be built in order to deal with the climate projections of future decades

·       the need to change the way the urban environment was built and securing as much of it as possible through new development, for example more trees to help with both rainwater and increasing temperatures

·       the work already undertaken and still to be done to change customer habits – Southern Water having an award-winning customer education programme, and one of the purposes of the DWMP being the broadening of this messaging (rainwater capturing and reuse etc), whilst also through such infrastructure as interceptors capturing as much as possible at source

·       acceptance that Southern Water’s track record was not great and that there had been some serious pollutions instances that they regretted and apologised for, but that they were determined to improve their performance and were working very hard to do that

·       being heavily regulated by the Environment Agency who set the permit levels Southern Water operated against, whilst also being regulated for the money that could be charged to customers, and the difficulties in balancing these two

·       concerning water resource management plans, being in a water-stressed part of the country but working closely with other water companies across the South East as part of the Water Resources South East Group to develop a water resources management plan for the next five-year period with the best value options to provide a safe and secure water supply for customers across the South East in the areas Southern Water served

·       it was explained that Southern Water did not receive guaranteed funding until a business case was put through Ofwat, which was done for a five-year period (currently 2020-25), so whilst Southern Water was setting out its investment needs for the next 25 years, its current business planning approach was to submit a business plan for the next five year investment period (2025-30) and price review plan which the DWMP was informing, in order to set out the level of funding needed to invest in infrastructure to provide a resilient drainage and wastewater service to customers going forward

·       water neutrality being a big issue in the north Sussex supply area and work being done with Horsham and Crawley District Councils to see how challenges could be addressed

·       water companies not being statutory consultees in the planning process so less able to influence design around water neutrality amongst other things

·       the need for building regulations to change in order to meet water neutrality, for example the average amount of water consumed by customers was 135 litres per person per day and though building regulations could push that down to 110 litres per person per day, in order to get to water neutrality that level really needed to get down to around 85 litres per person per day

·       most water being used to flush toilets, wash cars and water gardens, and the need to think about rainwater and grey water capture and recycling for these uses to really reduce levels of water consumption

·       the permits from the Environment Agency also covering the quality of the discharges with levels of pollution deemed harmful determined by the Environment Agency, and nutrient neutrality being influenced by the environmental capacity of the water body being discharged into and therefore should the amount of water in a body decrease in future due to drought then permit levels might need to be lowered

·       lobbying Government on better product labelling and discussions around banning non-flushable wet wipes through the trade body Water UK

·       the DWMP was helping Southern Water to explore the issues raised by Members and through its pathfinder projects was exploring mechanisms of how positive changes in behaviour could be incentivised (for example, drainage charges for rainwater getting into the sewer system)

·       the significant impact of groundwater levels on sewer systems, particularly where groundwater levels caused infiltration into the sewer system increasing the flow into treatment works and how this was an issue along the South Coast south of the South Downs

·       given the area’s topography and projections of summer storms of shorter duration but greater intensity in the future likely to overwhelm the sewer system, the drainage and wastewater strategy would have to be one of attenuation rather than separation in order to allow systems to cope

·       recognition of the importance of the beaches and internationally designated areas such as Pagham Harbour to the local economy and local communities and that improving the performance of systems was Southern Water’s number one priority by maximising the current infrastructure’s performance and making it more resilient, whilst at the same time putting in measures to minimise system failures and responding more rapidly when these do happen to avoid pollution incidents occurring

·       recognition that the sewer system was Victorian in original and designed for a different climate and population size, but that due to the size of the network, the level of investment would not enable Southern Water to proactively replace all sewers and so instead critical sewers were targetted for proactive maintenance and any smaller diameter sewer collapse or failure was responded to as rapidly as possible

·       in response to the Director of Growth’s question on nutrient neutrality and whether Southern Water would be applying the legal duty on water companies in nutrient neutrality areas to upgrade sewer systems to the highest achievable technological levels as indicated by the Government in its forthcoming Levelling Up and Regeneration Bill as its default position for upgrade works across the Arun area, the answer was no due to issues of affordability for customers as regulated by Ofwat whilst balancing what the Environment Agency asked to be delivered against affordable levels of investment. The Director of Growth suggested to Members that they may wish Officers to make representations to the District’s MPs as part of the Levelling Up Bill process that nutrient neutrality apply across all Local Planning Authorities regardless of whether they had been designated as nutrient neutral already. The Leader of the Council noted, from discussions he had had with MPs in recent weeks, that this was a live issue and that he would endeavour to make those representations

The Planning Policy Team Leader provided Members with responses to points raised during the debate, including:

·       confirmation that the Local Plan did include a number of policies that tried to address the environmental impact of built development such as the sustainable design guide

·       that when the Local Plan update was resumed, the evidence base would also be updated to improve the application and impact of these policies through tougher standards

The recommendation was then proposed by Councillor Hughes and seconded by Councillor Thurston.

The Committee

RESOLVED

That the proposed consultation response to the Drainage Wastewater Management Plan consultation be agreed.