Tandridge District Council Water Cycle Study - Phase 1 Scoping Study - Final
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Tandridge District Council Water Cycle Study – Phase 1 Scoping Study Final May 2018 www.jbaconsulting.com Tandridge District Council Council Offices Station Road East Oxted Surrey RH8 0BT 2018s0255 TDC WCS Phase 1 Scoping v3.0 i
JBA Project Manager
Alistair Clark
8a Castle Street
Wallingford
Oxfordshire
OX10 8DL
Revision history
Revision Ref/Date Amendments Issued to
17/04/2018 v1 Draft Report Mark Bristow
04/05/2018 v2 Minor amendments in Mark Bristow
response to comments from
TDC.
11/05/2018 v3 Final Report Mark Bristow
Contract
This report describes work commissioned by Tandridge District Council in February 2018.
Tandridge District Council’s representative for the contract was Mark Bristow. Alistair Clark and
Richard Pardoe of JBA Consulting carried out this work.
Prepared by .................................. Richard Pardoe MSc MEng
Analyst
Reviewed by .................................. Alistair Clark BSc MSc
Senior Analyst
Purpose
This document has been prepared as a Final Report for Tandridge District Council. JBA
Consulting accepts no responsibility or liability for any use that is made of this document other
than by the Client for the purposes for which it was originally commissioned and prepared.
JBA Consulting has no liability regarding the use of this report except to Tandridge District
Council.
Acknowledgements
JBA Consulting would like to thank Mark Bristow of Tandridge District Council, Southern Water,
Sutton and East Surrey Water and Thames Water for their assistance in preparing this report.
Copyright
© Jeremy Benn Associates Limited 2018.
2018s0255 TDC WCS Phase 1 Scoping v3.0 i
Carbon footprint A printed copy of the main text in this document will result in a carbon footprint of 313g if 100% post-consumer recycled paper is used and 399g if primary-source paper is used. These figures assume the report is printed in black and white on A4 paper and in duplex. JBA is aiming to reduce its per capita carbon emissions. 2018s0255 TDC WCS Phase 1 Scoping v3.0 ii
Executive summary
In March 2018, JBA Consulting was commissioned by Tandridge District Council to
undertake a Water Cycle Study (WCS). This study assesses the potential issues relating to
future development within the Tandridge district and the impacts on water supply,
wastewater collection and waste water treatment. The Water Cycle Study is required to
assess the constraints and requirements that will arise from potential growth on the water
infrastructure.
New homes require the provision of clean water, safe disposal of wastewater and protection
from flooding. The allocation of large numbers of new homes in certain locations may result
in the capacity of existing available infrastructure being exceeded, a situation that could
potentially cause service failures to water and wastewater customers, adverse impacts to
the environment, or high costs for the upgrade of water and wastewater assets being
passed on to the bill payers.
In addition to increased housing demand, future climate change presents further challenges
to pressures on the existing water infrastructure network, including increased intensive
rainfall events and a higher frequency of drought events. Sustainable planning for water
must now take this into account. The water cycle can be seen in the figure below, and
shows how the natural and man-made processes and systems interact to collect, store or
transport water in the environment.
The Water Cycle
Source: Environment Agency – Water Cycle Study Guidance
2018s0255 TDC WCS Phase 1 Scoping v3.0 iii
This study will assist the council to select and develop sustainable development allocations
where there is minimal impact on the environment, water quality, water resources,
infrastructure, and flood risk. This has been achieved by identifying areas where there may
be conflict between any proposed development, the requirements of the environment and
by recommending potential solutions to these conflicts.
The purpose of this Phase 1 Scoping Study is to document the growth forecast, gather the
available data and define the methodology that will be used in the Phase 2 Outline Study.
Potential development sites were provided by Tandridge District Council and wastewater
treatment works (WwTW) likely to serve growth in the area were identified using the
Environment Agency Consents database. Each development site was then allocated to a
WwTW in order to understand the additional wastewater flow resulting from the planned
growth. Available information was collated on water policy and legislation, water resources,
water quality, and environmental designations within the study area and used to assess the
requirements for further study in Phase 2. Where further study is required, a proposed
methodology is provided.
The following assessments are required in the Outline Study:
• Water resources
• Water supply infrastructure
• Wastewater collection infrastructure
• Wastewater treatment capacity
• Water quality
• Odour from WwTW
• Flood risk from additional foul flow
• Environmental constraints
2018s0255 TDC WCS Phase 1 Scoping v3.0 iv
Contents 1 Introduction 1 1.1 Terms of Reference 1 1.2 The Water Cycle 1 1.3 Impacts of Development on the Water Cycle 2 1.4 Objectives 2 1.5 Study Area 3 1.6 Record of Engagement 3 1.6.1 Introduction 3 1.6.2 Scoping Study Engagement 3 2 Future Growth in Tandridge 4 2.1 Tandridge District 4 2.2 Growth in Tandridge 5 2.3 Components of development forecast 5 2.4 Housing 5 2.4.1 Housing and Economic Land Availability Assessment 5 2.4.2 Garden village sites 6 2.4.3 Commitments 6 2.4.4 Windfall 7 2.4.5 Growth by parish 8 2.4.6 Summary 8 2.5 Employment Land 9 2.5.1 Economic Needs Assessment 9 2.5.2 Employment land 9 2.6 Growth in Neighbouring LPAs 10 2.6.1 Introduction 10 2.6.2 Reigate and Banstead 10 2.6.3 Crawley 10 2.6.4 Mid Sussex District Council 11 2.6.5 Sevenoaks District Council 12 3 Legislative and Policy Framework 13 3.1 Introduction 13 3.2 National Policy 13 3.2.1 National Planning Policy Framework 13 3.2.2 Planning Practice Guidance: Flood Risk and Coastal Change 14 3.2.3 Planning Practice Guidance: Water Supply, Wastewater and Water Quality 16 3.2.4 Planning Practice Guidance: Housing – Optional Technical Standards 17 3.2.5 Building Regulations and Code for Sustainable Homes 17 3.2.6 BREEAM 17 3.2.7 Sustainable Drainage Systems (SuDS) 18 3.3 Regional Policy 19 3.3.1 Catchment Flood Management Plans 19 3.3.2 Surface Water Management Plans (SWMPs) 19 3.3.3 Water Resource Management Plans 20 3.4 Local Policy 20 3.4.1 Localism Act 20 3.4.2 Local Plan and Local Strategy 20 3.4.3 Infrastructure Delivery Plan 21 2018s0255 TDC WCS Phase 1 Scoping v3.0 v
3.5 Environmental Policy 21 3.5.1 Urban Wastewater Treatment Directive (UWWTD) 21 3.5.2 Habitats Directive 21 3.5.3 The Water Framework Directive 22 3.5.4 Protected Area Objectives 22 3.5.5 Groundwater Source Protection Zones 23 3.5.6 European Derived Legislation and Brexit 24 3.6 Water Industry Policy 25 3.6.1 The Water Industry in England 25 3.6.2 Regulations of the Water Industry 25 3.6.3 Developer Contributions and Utility Companies 25 3.6.4 Changes to Charging Rules for New Connections 26 4 Water Resources and Water Supply 27 4.1 Introduction 27 4.1.1 Surface Waters 27 4.1.2 Geology 28 4.2 Availability of Water Resources 30 4.2.1 Overview of Water Resource Management 30 4.3 Resource Availability Assessment 32 4.3.1 London ALS 32 4.3.2 Medway ALS 33 4.3.3 Mole ALS 34 4.3.4 Darent and Cray ALS 34 4.3.5 Recommendations for Better Management Practices 35 4.3.6 Water Stress 35 4.3.7 Water Resource Assessment: Water Resource Management Plans 35 4.3.8 Sutton and East Surrey Water Resource Zone 35 4.3.9 Population and Household Growth 37 4.3.10 Per-Capita Consumption 37 4.3.11 Supply-demand balance 38 4.3.12 Impact of climate change 38 4.3.13 SESW’s Preferred Plan 38 4.4 Conclusions 39 4.5 Water Supply Infrastructure 40 4.5.1 Introduction 40 4.5.2 Capacity for Growth within Tandridge 40 4.5.3 Conclusions 40 4.5.4 Proposed Methodology for Outline Study 40 5 Wastewater collection 41 5.1 Sewerage Undertaker for Tandridge 41 5.2 Sewerage System Capacity Assessment 41 5.2.1 Combined Sewer Overflows 42 5.3 Conclusions 42 5.4 Proposed methodology for outline study 42 6 Wastewater Treatment and Water Quality 43 6.1 Assessing Wastewater Flow and Water Quality 43 6.1 Wastewater Treatment Flow Permit Assessment 43 6.1.1 Introduction 43 6.2 Identification of WwTWs 44 6.3 Water framework directive 47 6.4 Conclusions 48 2018s0255 TDC WCS Phase 1 Scoping v3.0 vi
6.5 Proposed methodology for Outline Study 48 6.5.1 Data Requirements 48 6.5.2 Flow permit assessment 48 6.5.3 Water quality assessment 49 7 Flood Risk Management 51 7.1 Assessment of Additional Flood Risk from Increased WwTW Discharges 51 7.2 Proposed methodology for outline study 51 8 Odour Assessment 52 8.1 Introduction 52 8.2 High Level odour assessment 52 8.3 Conclusions 53 8.4 Proposed methodology for outline study 53 9 Environmental Opportunities and Constraints 54 9.1 Sites with Environmental Designation 54 9.2 Conclusions 60 9.3 Recommendations for outline study 60 10 Phase 2 - Outline Study 61 10.1 Requirements for outline study 61 10.2 Impact of climate change 62 2018s0255 TDC WCS Phase 1 Scoping v3.0 vii
List of Figures Figure 1.1 The Water Cycle 2 Figure 2.1 Map of the water cycle study area and potential development sites 4 Figure 3.1 Flood Risk and the Preparation of Local Plans 15 Figure 3.2 PPG: Water supply, wastewater and water quality considerations for plan- making and planning applications 16 Figure 4.1 Watercourses within the study area 27 Figure 4.2 Bedrock geology of Tandridge 29 Figure 4.3 Superficial geology of Tandridge 30 Figure 4.4 Abstraction Licencing Strategy areas 31 Figure 4.5 Sutton and East Surrey Water Resource Zone 36 Figure 6.1 Overview of typical combined sewerage system and WwTW discharges 44 Figure 6.2 Location of Wastewater treatment works within or close to the Tandridge boundary 45 Figure 6.3 WFD status of receiving waterbodies 47 Figure 8.1 Zones with potential to be affected by odour from WwTW 52 Figure 9.1 Sites with environmental designations 54 Figure 9.2 Impact Risk Zones for residential developments 56 Figure 9.3 Impact Risk Zones for rural residential development 57 Figure 9.4 Impact Risk Zones for non-residential development 58 Figure 9.5 Impact Risk Zones for discharge of water or liquid waste 59 List of Tables Table 2.1 Indicative figures for housing and employment in garden village sites 6 Table 2.2 Historic windfall sites within TDC 7 Table 2.3 Allocation of windfall by WwTW 7 Table 2.4 Housing units by parish 8 Table 2.5 Summary of housing development 8 Table 2.6 Indicative number of employees by parish 9 Table 2.7 Summary of growth in Reigate and Banstead Borough that could affect shared infrastructure with Tandridge 10 Table 2.8 Summary of growth in Crawley Borough that could affect shared infrastructure with Tandridge 11 Table 2.9 Summary of growth in Crawley Borough that could affect shared infrastructure with Tandridge 12 Table 2.10 Summary of growth in Crawley Borough that could affect shared infrastructure with Tandridge 12 Table 3.1 BREEAM credits for percentage improvement over baseline water consumption 18 Table 4.1: Implications of Surface Water Resource Availability Colours 32 Table 4.2 Summary of resource availability in Medway CAMS area 33 Table 4.3 Summary of resource availability in Mole CAMS area 34 Table 4.4 Summary of growth forecasts 37 Table 4.5 SESW's preferred plan 38 Table 6.1 Indicative growth served by each WwTW (Realistic scenario) 46 Table 6.2 Data required for WwTW flow and water quality assessments 48 Table 9.1 Sites within an impact risk zone for residential development 55 Table 9.2 Development sites within impact risk zones for non-residential development 58 Table 10.1 Summary out requirements for outline study 61 Table 10.2 Climate change pressures scoring matrix 62 2018s0255 TDC WCS Phase 1 Scoping v3.0 viii
Abbreviations
ALS Abstraction Licensing Strategy
AMP Asset Management Plan
AMR Automatic Meter Reading
AONB Area of Outstanding Natural Beauty
AP Assessment Point
ASNW Ancient Semi-Natural Woodland
BERR Department for Business Enterprise and Regulatory Reform
BIDS Business, Industrial, Distribution and Storage
BOD Biochemical Oxygen Demand
BREEAM Building Research Establishment Environmental Assessment
Methodology
CAMS Catchment Abstraction Management Strategies
CAPEX Capital Expenditure
CED Common End Date
CFMP Catchment Flood Management Plan
CfSH Code for Sustainable Homes
CLP Comprehensive Local Plan
CSO Combined Sewer Overflow
DCLG Department of Communities and Local Government
DWF Dry Weather Flow
DWI Drinking Water Inspectorate
DYAA Dry Year Annual Average
DYCP Dry Year Critical Period
EA Environment Agency
EC European Community
ECA European Communities Act
EDNA Economic Development Needs Assessment
EFI Ecological Flow Indicator
EP Environmental Permit
EU European Union
FEH Flood Estimation Handbook
FFT Flow to Full Treatment
FWMA Flood and Water Management Act
FZ Flood Zone
GES Good Ecological Status
GIS Geographic Information Systems
HOF Hands-Off Flow
HOL Hands-off Level
IDB Internal Drainage Board
IDP Infrastructure Delivery Plan
JBA Jeremy Benn Associates
LLFA Lead Local Flood Authority
LPA Local Planning Authority
2018s0255 TDC WCS Phase 1 Scoping v3.0 ixl/p/d Litres per person per day Ml/d Mega (Million) litres per day NE Natural England NH4 Ammonia NPPF National Planning Policy Framework NYAA Normal Year Average Annual OAN Objectively Assessed Need OfWAT Water Service Regulation Authority ONS Office of National Statistics OPEX Operational Expenditure OS Ordnance Survey P Phosphorous PDL Previously Developed Land PE Population Equivalent p/h Person per house PPS Planning Policy Statement RAG Red / Amber / Green assessment RBD River Basin District RBMP River Basin Management Plan ReFH Revitalised Flood Hydrograph RNAG Reason for Not Achieving Good (Status) RQP River Quality Planning tool RZ Resource Zone SA Sustainability Appraisals SAC Special Area of Conservation SBP Strategic Business Plan SEA Strategic Environmental Assessment SEPA Scottish Environmental Protection Agency SESW Sutton and East Surrey Water SFRA Strategic Flood Risk Assessment SHELAA Strategic Housing and Economic Land Availability Assessment SHMA Strategic Housing Market Assessment SPA Special Protection Area SPD Supplementary Planning Document SPZ Source Protection Zone SS Suspended Solids SSSI Site of Special Scientific Interest SU Sewerage Undertaker SW Southern Water SuDS Sustainable Drainage Systems SWMP Surface Water Management Plan TCAMS Thames Catchment Abstraction Management Strategy TDC Tandridge District Council TW Thames Water 2018s0255 TDC WCS Phase 1 Scoping v3.0 x
uFMfSW Updated Flood Map for Surface Water UWWTD Urban Waste Water Treatment Directive WaSC Water and Sewerage Company WCS Water Cycle Study WFD Water Framework Directive WRC Water Recycling Centre WRMP Water Resource Management Plan WRZ Water Resource Zone WQA Water Quality Assessment WSZ Water Supply Zone WTW Water Treatment Works WwTW Wastewater Treatment Works 2018s0255 TDC WCS Phase 1 Scoping v3.0 xi
1 Introduction
1.1 Terms of Reference
JBA Consulting was commissioned by Tandridge District Council to undertake a Water Cycle
Study (WCS) for Tandridge district to inform the Local Plan. The purpose of the WCS along
with the Strategic Flood Risk Assessment (SFRA) is to form part of a comprehensive and
robust evidence base for the Local Plan which will set out a vision and framework for
development in the area up to 2033 and will be used to inform decisions on the location of
future development.
Unmitigated future development and climate change can adversely affect the environment
and water infrastructure capability. A WCS will provide the required evidence, together
with an agreed strategy to ensure that planned growth occurs within environmental
constraints, with the appropriate infrastructure in place in a timely manner so that planned
allocations are deliverable.
1.2 The Water Cycle
National Planning Policy Framework Practice Guidance on Water Supply, Wastewater and
Water Quality1 describes a water cycle study as:
"a voluntary study that helps organisations work together to plan for sustainable growth. It uses water
and planning evidence and the expertise of partners to understand environmental and infrastructure
capacity. It can identify joined up and cost-effective solutions, that are resilient to climate change for the
lifetime of the development.
The study provides evidence for Local Plans and sustainability appraisals and is ideally done at an early
stage of plan-making. Local authorities (or groups of local authorities) usually lead water cycle studies,
as a chief aim is to provide evidence for sound Local Plans but other partners often include the
Environment Agency and water companies."
The Environment Agency's guidance on WCS 2 recommends a phased approach:
• Phase 1: Scoping study, focussing on formation of a steering group, identifying
issues for consideration and the need for an outline study.
• Phase 2: Outline study, to identify environmental constraints, infrastructure
constraints, a sustainability assessment and consideration of whether a detailed
study is required.
• Phase 3: Detailed study, to identify infrastructure requirements, when they are
required, how they will be funded and implemented and an overall assessment of
the sustainability of proposed infrastructure.
Figure 1.1 below shows the main elements that compromise the Water Cycle and shows
how the natural and man-made processes and systems interact to collect, store or transport
water in the environment.
—————————————————————————————————————————————
1 Planning Practice Guidance: Water supply, wastewater and water quality, Department for Communities and Local Government (2014).
Accessed online at: http://planningguidance.planningportal.gov.uk/blog/guidance/ on: 09/03/2018
2 Water Cycle Study Guidance, Environment Agency (2009). Accessed online at:
http://webarchive.nationalarchives.gov.uk/20140328084622/http://cdn.environment-agency.gov.uk/geho0109bpff-e-e.pdf on:
09/03/2018
2018s0255 TDC WCS Phase 1 Scoping v3.0 1Figure 1.1 The Water Cycle
1.3 Impacts of Development on the Water Cycle
New homes require the provision of clean water, safe disposal of wastewater and protection
from flooding. It is possible that allocating large numbers of new homes at some locations
may result in the capacity of the existing available infrastructure being exceeded. This
situation could potentially lead to service failures to water and wastewater customers, have
adverse impacts on the environment or cause the high cost of upgrading water and
wastewater assets being passed on to bill payers. Climate change presents further
challenges such as increased intensity and frequency of rainfall and a higher frequency of
drought events that can be expected to put greater pressure on the existing infrastructure.
1.4 Objectives
As a WCS is not a statutory instrument, Local Planning Authorities are advised to prioritise
the different stages of the WCS to integrate with their Local Plan programme. This scoping
report is written as an interim report to support the development of the Comprehensive
Local Plan (CLP) and to identify whether an outline / detailed WCS is required. Specific
requirements, specified by the project brief, were to:
• Provide a scoping report, taking into account guidance in the NPPF, NPPG, The
Water Framework Directive, The Thames River Basin Management Plan and the
EA Water Cycle Study Requirements and Guidance – Thames Area (September
2016);
• Produce an effective water cycle study in the context of the scoping stage so that:
o New development takes place only within environmental constraints;
o New development occurs in the most sustainable location, in relation to the
water environment;
o Water cycle infrastructure is in place before new development is occupied
and;
o Opportunities for more sustainable infrastructure options are realised.
• Quantify growth within the study area
• Include the outcomes of stakeholder engagement within the scoping study;
• Gather, assess and use existing data and evidence available, in order to prepare
the scoping report and address specific questions;
• Determine any gaps in knowledge/evidence;
2018s0255 TDC WCS Phase 1 Scoping v3.0 2• Identify any environmental and major infrastructure constraints;
• Where relevant, cross reference with the replacement Strategic Flood Risk
Assessment currently being prepared and its outcomes;
• Identification of the issues and questions to be considered with regards to water
resources and water quality;
• Establish whether an outline study is required and define its required scope.
1.5 Study Area
This WCS scoping report has been written for Tandridge District Council. This Local
Authority area covers 248km2 and includes the towns of Caterham, Godstone, Lingfield,
and Oxted and has a population of approximately 87,000.
The area is located within the River Mole, and River Medway catchments to the west and
east respectively. The area north of the North Downs is in the catchment of the Caterham
Bourne.
Water supply services for Tandridge are provided by Sutton and East Surrey Water, and
wastewater serves are split between Thames Water and Southern Water.
1.6 Record of Engagement
1.6.1 Introduction
Preparation of a WCS requires significant engagement with stakeholders, both within the
Local Planning Authority, with water and wastewater utilities, with the Environment Agency,
and where there may be cross-boundary issues, with neighbouring local authorities. This
section forms a record of engagement for the WCS.
1.6.2 Scoping Study Engagement
The preparation of the scoping study was supported by the following engagement:
Water company conference call
Engaged TDC
Parties Southern Water
Sutton and East Surrey Water
Thames Water
Details Scope of works and data collection requirements reviewed.
Neighbouring authorities
Engaged TDC
Parties Crawley Borough Council
Mid Sussex District Council
Reigate and Banstead Borough Council
Sevenoaks District Council
Details Request for water cycle studies conducted in their area,
and housing growth that would be served by WwTW within
or shared with TDC.
Croydon Borough Council and Bromley Borough Council were not engaged as part of the
phase 1 scoping study. Growth from these areas is served either by infrastructure not
shared with Tandridge, or by Beddington WwTW. In the case of Beddington WwTW, this
works takes waste water from a large number of LPAs and an assessment of all growth that
might be served by Beddington is outside of the scope of this WCS.
2018s0255 TDC WCS Phase 1 Scoping v3.0 32 Future Growth in Tandridge
2.1 Tandridge District
Figure 2.1 shows the location of potential development sites within the TDC boundary.
Figure 2.1 Map of the water cycle study area and potential development sites
2018s0255 TDC WCS Phase 1 Scoping v3.0 42.2 Growth in Tandridge
The Strategic Housing Market Assessment (SHMA)3 carried out in 2015 provided a detailed
analysis of population demographics and the housing market within Tandridge and resulted
in the definition of the Objectively Assessed Need (OAN)4 for the district.
This assessment was based on the Department for Communities and Local Government
(DCLG) 2012-based household projections, updated with the 2014 mid-year estimates
released in June 2015 and the international migration statistics for the year up to March
2015.
The conclusion of the assessment was that a total of 9,440 houses were required during
the plan period (2013-2033) or an average of 470 / year.
2.3 Components of development forecast
For the purpose of the assessments within the WCS, a baseline growth forecast is defined
for development in Tandridge over the Local Plan period. This forecast is made up of the
following components:
• Housing and Economic Land Availability Assessment (HELAA)
• Garden village sites
• Commitments (development sites already in the planning system, but not yet
built)
• Windfall
• Development from outside the Tandridge boundary, but served by infrastructure
within or shared with Tandridge (this forecast has not yet been received from
neighbouring LPAs so is not included in this report, however this will be
documented in the Phase 1 report and included in future assessments)
These have been collated into an overall forecast summarised in Table 2.5 below.
2.4 Housing
2.4.1 Housing and Economic Land Availability Assessment
The Tandridge District Council Housing and Economic Land Availability Assessment
(HELAA)5 is an important piece of evidence in preparing local plans and identifies possible
sites for future housing and economic development. It also contains an assessment of
development potential, suitability, likelihood and timing of development. It does not
determine whether a site should be allocated; this decision remains part of the local
planning process.
The sites identified in the HELAA were filtered by TDC and list of preferred options were
provided for analysis in this water cycle study. For the purpose of this study, all of these
sites are assumed to be adopted in the Local Plan.
The following assumptions taken from the HELAA document were applied to the list of sites
in order to create a notional housing trajectory:
• A site accommodating up to 20 dwellings would take a year to build out;
—————————————————————————————————————————————
3 Strategic Housing Market Assessment, TDC (2015). Accessed online at:
https://www.tandridge.gov.uk/Portals/0/Documents/Planning%20and%20building/Planning%20strategies%20and%2
0policies/Local%20plan/Evidence%20base%20and%20technical%20studies/Strategic-Housing-Market-Assessment-
2015-Front-Page.pdf on: 26/02/2018
4 The Objectively Assessed Housing Needs of Tandridge, NMSS (2015). Accessed online at:
https://www.tandridge.gov.uk/Portals/0/Documents/Planning%20and%20building/Planning%20strategies%20and%2
0policies/Local%20plan/Evidence%20base%20and%20technical%20studies/Strategic-Housing-Market-Assessment-
2015-Tandridge-Objectively.pdf on: 26/02/2018
5 The HELAA is an evolving document containing a number of appendices. The latest version can be found on the TDC website:
https://www.tandridge.gov.uk/Planning-and-building/Planning-strategies-and-policies/Local-Plan-2033-emerging-
planning-policies/Local-Plan-2033/Evidence-base-and-technical-studies Accessed online on: 27/02/2018
2018s0255 TDC WCS Phase 1 Scoping v3.0 5• A site accommodating between 21 and 60 dwellings would take 2 years to build
out;
• A site accommodating between 61 and 99 dwellings would take 3 years to build
out;
• A site accommodating between 100 and 399 dwellings would be built out at a rate
of 65 dwellings per year (assumes a single developer);
• A site accommodating between 400 and 999 dwellings would be built out at a rate
of 130 dwellings per year (assumes 2 developers); and
• A site accommodating 1000 or more dwellings would be built out at a rate of 200
dwellings per year (assumes 3 developers).
• Completions on sites assessed as being developable would begin in the
2021/2022 monitoring year
At the time of writing and for the purpose of this study, development in the garden village
sites is assumed to be spread over the local plan period, commencing in 2025/26.
2.4.2 Garden village sites
The Spatial Approaches Topic Paper (2015)6 presented the concept of a new or extended
settlement as a route to deliver the growth required within the district. Three broad
locations are considered within the WCS:
• Redhill Aerodrome
• South Godstone
• Blindley Heath
In the phase 2 outline study, two scenarios will be tested, the first where one garden village
site is adopted, South Godstone has been chosen for this purpose. The second tests the
unlikely event of the Council being expected to provide three garden village sites
representing the most extreme case for water demand.
Table 2.1 Indicative figures for housing and employment in garden village sites
Broad Location Housing Employment (no.
units of employees)
Redhill Aerodrome 7000 2822
South Godstone 4000 2615
Blindley Heath 3000 2619
Consideration of these broad locations is at a very early stage; the estimates of housing
units and employment land are indicative only. It is therefore prudent to consider the effect
on water infrastructure if the size of the development was increased, or the mix of housing
and employment land was changed such that the water demand increased. A further
scenario will therefore be considered in the outline study where the garden village site water
and wastewater demand are increased by 10%.
2.4.3 Commitments
TDC provided details of committed sites within their district. These are sites that are
currently in the planning system so do not appear within the HELAA but have not yet been
completed so are not taken into account in the current water demand.
—————————————————————————————————————————————
6 Spatial Approaches Topic Paper, TDC (2015). Accessed online at:
https://www.tandridge.gov.uk/Portals/0/Documents/Planning%20and%20building/Planning%20strategies%20and%20policies/Local%
20plan/Evidence%20base%20and%20technical%20studies/Spatial-Approaches-Topic-Paper.pdf on: 27/02/2018
2018s0255 TDC WCS Phase 1 Scoping v3.0 6On the Site Tracker spreadsheet, they have each been allocated to a WwTW based on their
location and proximity to existing housing.
2.4.4 Windfall
Windfall sites are sites that have not been specifically identified in the Local Plan. They
normally comprise previously developed sites that have unexpectedly become available.
The council proposes to only include windfall allowance for sites capable of accommodating
less than 5 net dwellings on the assumption that larger developments will be identified
through the HELAA process.
Table 2.2 Historic windfall sites within TDC
Total Small Site
Total Small Site
Windfall
Total Small Site Windfall
Completions
Year Windfall Completions on
Excluding
Completions Residential
Residential
Garden Land
Garden Land
2006/2007 53 19 34
2007/2008 51 26 25
2008/2009 40 17 23
2009/2010 46 21 25
2010/2011 37 16 21
2011/2012 39 12 27
2012/2013 64 31 33
2013/2014 82 41 41
2014/2015 38 20 18
2015/2016 66 33 33
Average 51.6 23.6 28.0
Source: Tandridge District Council (2016) Housing and Economic Land Availability Assessment, October 2016. Updated with 2016/2017
Data.
The council have decided to exclude the residential garden land development from the
overall windfall allowance. The figure used throughout the rest of this study will therefore
be 27 dwellings per year.
This will be allocated to wastewater treatment works (Table 2.3) within Tandridge based on
the percentage of growth within each catchment from other sources (HELAA and
Commitments).
Table 2.3 Allocation of windfall by WwTW
Wastewater % of Windfall
Treatment Works
Beddington STW 60%
Burstow STW 11%
Earlswood 2%
(Reigate) STW
Godstone STW 8%
Lingfield STW 4%
Oxted and 15%
Limpsfield STW
2018s0255 TDC WCS Phase 1 Scoping v3.0 72.4.5 Growth by parish
Table 2.4 shows the allocation of homes by parish. These figures assume that every
identified site is allocated in the Local Plan and represents the most extreme case.
Table 2.4 Housing units by parish
Parish Housing Units
Bletchingley 7
Burstow 339
Caterham-on-the-Hill 320
Caterham Valley 465
Chaldon 1
Crowhurst 12
Dormansland 12
Felbridge 8
Godstone* 7221
Horne 5
Limpsfield 24
Lingfield 98
Nutfield** 7021
Oxted 403
Tatsfield 9
Titsey -
Warlingham 536
Whyteleafe 391
Woldingham 17
Windfall 504
Total 17425
*Assumes both South Godstone (4000 homes) and Blindley Heath (3000 homes) garden village sites adopted
**Assumes Redhill Aerodrome garden village site adopted (7000 homes of which approximately 4,000 would be within Tandridge District)
2.4.6 Summary
Table 2.5 summarises the development within Tandridge. The most realistic scenario
includes just one garden village site (South Godstone has been chosen for this analysis).
Table 2.5 Summary of housing development
Housing units (All Housing units
sites) (Realistic scenario)
Completions 2013 to 2017 1,518 1,518
Commitments 2017/2018 1,115 1,115
HELAA 1,806 1,806
Garden Village * 14,000 4,000
Windfall 2013-2033 540 540
Total 18,979 8,979
Objectively Assessed Need 9,400 9,400
*A proportion of development within the garden village site will come forward outside of the local plan period. The full development will
be considered within this WCS.
2018s0255 TDC WCS Phase 1 Scoping v3.0 82.5 Employment Land
2.5.1 Economic Needs Assessment
The Economic Needs Assessment 7 for Tandridge was updated in November 2017 and
summarises the forecast economic growth in the district and its resultant requirement for
land.
Two scenarios were presented, a baseline scenario based on the econometric forecast from
Experian (Dated March 2017), and growth scenario based on the baseline plus a part return
to the historic trend, business surveys and the SEP aspirations. These two scenarios
estimate the employment land requirement as:
Baseline scenario – 15.3 ha
Growth scenario – 22.5 ha
2.5.2 Employment land
Table 2.6 summarises the employment forecast by parish and includes employment from
all three garden village sites. The number of employees is indicative only, based on the
proposed land use.
Table 2.6 Indicative number of employees by parish
Parish Indicative number of
employees
Bletchingley -
Burstow 103
Caterham-on-the-Hill 40
Caterham Valley 279
Chaldon -
Crowhurst 2
Dormansland 156
Felbridge 790
Godstone* 5448
Horne 76
Limpsfield 551
Lingfield 19
Nutfield** 2869
Oxted 126
Tatsfield 14
Titsey 2
Warlingham 4
Whyteleafe 24
Woldingham -
Windfall -
Oxted and Limpsfield STW 10503
*Assumes both South Godstone (2816 employees) and Blindley Heath (2619 employees) garden village sites adopted
**Assumes Redhill Aerodrome site adopted (2822 employees)
—————————————————————————————————————————————
7Tandridge Economic Needs Assessment Update, TDC (2017). Accessed online at:
https://www.tandridge.gov.uk/Portals/0/Documents/Planning%20and%20building/Planning%20strategies%20and%2
0policies/Local%20plan/Local%20plan%202033/Technical%20Assessment%20documents%20published%20in%2020
17/Tandridge-Economic-Needs-Assessment-Update-Nov17.pdf on: 27/02/2018
2018s0255 TDC WCS Phase 1 Scoping v3.0 92.6 Growth in Neighbouring LPAs
2.6.1 Introduction
Neighbouring authorities were approached under a duty to cooperate request to understand
how growth in neighbouring authorities may impact water infrastructure within or shared
with Tandridge. This allows the full picture of growth to be taken into account when carrying
out flow capacity and water quality assessments.
Each council was asked for the following information:
• Has a water cycle study been completed for your area? If yes, can you provide a
link?
• The latest forecast (housing and employment) for your district for the period up to
2033.
• Details of future growth within catchments of the WwTW which serve part of your
council area and Tandridge.
A table was provided for each council to complete, listing the WwTW that may be shared
with their area. It was decided not to contact Croydon Borough Council. The only shared
infrastructure is Beddington WwTW which is a very large works covering multiple
authorities. The proportion of growth from Tandridge is likely to be very small and so it is
not proposed that this WwTW is assessed as part of this study.
2.6.2 Reigate and Banstead
The Borough of Reigate and Banstead borders Tandridge to the west. A high-level water
cycle study was undertaken for the Gatwick area in 20118, and included part of Reigate and
Banstead. The council reported housing growth in their area of 5,654 units up to 2033, and
employment growth of 224,000m2 (which includes their proposed Horley strategic
employment site, HOR9).
Table 2.7 Summary of growth in Reigate and Banstead Borough that could affect
shared infrastructure with Tandridge
WwTW Housing Units Employment (m2)
Committed Allocated Committed Allocated
Reigate 289 1,107 -10,108 8,000
STW
Merstham 48 215 -760 0
STW
Committed employment figures are provided as net, taking into account the loss of
commercial space due to a change use to residential.
2.6.3 Crawley
Crawley Borough shares a border with south west Tandridge and were also part of the
Gatwick WCS mentioned above. Entec were commissioned to prepare a Crawley specific
WCS9 to inform the (now adopted) Local Plan.
The objectively Assessed Housing Need for Crawley over the plan period 2015-2030 is
10,125 dwellings. As a result of Crawley’s constrained land supply position, the Local Plan
takes a supply-led approach, making provision for a minimum of 5,100 net dwellings over
the plan period to 2030 (Local Plan Policy H1).
—————————————————————————————————————————————
8 Gatwick Sub Region Outline Water Cycle Study, Entec (2011). Accessed online at:
http://www.reigate-banstead.gov.uk/info/20088/planning_policy/22/evidence_and_research_for_planning_policies/6 on: 13/04/2018
9 Crawley Borough Council Water Cycle Study Update and Review of Policy Implications, Amec (2013). Accessed online at:
http://www.crawley.gov.uk/pw/web/pub206690 on: 13/04/2018
2018s0255 TDC WCS Phase 1 Scoping v3.0 10For employment, the Crawley Borough Local Plan identifies a total need for 57.9 hectares
of business land over the plan period to 2030. This equates to a total business floorspace
of 287,190m2. As for housing, a supply-led approach has been taken, identifying
opportunities for approximately 23 hectares of business land (114,072m 2). The local plan
does not allocate any new employment land, though identifies the existing main
employment areas as a focus for economic growth. There remains an unmet need of 35
hectares.
For retail, the supporting text (5.64) to Local Plan Policy EC7 identifies capacity for up to
26,650m2 of comparison retail floorspace. There is a current over-supply of convenience
retail floorspace, so no figure is provided within the Local Plan. The Local Plan does not
specifically allocate land to accommodate new retail floorspace, instead directing this to the
most sequentially-preferable sites.
Table 2.8 Summary of growth in Crawley Borough that could affect shared
infrastructure with Tandridge
WwTW Housing Units Employment (m2) Notes
Committed Allocated Committed Allocated
Burstow NA N/A N/A N/A The majority of Crawley
is serviced by Crawley
WwTW, with a small area
in the north (parts of
Gatwick Airport) served
by Horley WwTW. Land
served by Burstow
WwTW falls outside of
Crawley’s administrative
boundary (please see
p19-22 of the 2013 WCS
update)
Crawley 3379 1237 112,131 0 *This comprises active
m2* permissions for B-class
business floorspace and
development that has
commenced on site and
currently being built out.
Please also note that as
a result of office to
residential conversions
falling under the
‘committed’ heading,
there is anticipated to be
a corresponding loss of
some 25,961sqm
business floorspace. The
figure in the ‘committed’
column does not factor in
this loss, and it would
need to be subtracted
manually should you
wish to factor in
floorspace lost.
2.6.4 Mid Sussex District Council
Mid Sussex shares Tandridge’s southern border and were also included in the Gatwick WCS.
They have stated their minimum housing requirement for 2014-2031 as 16,390. The
average number of houses provided for over the whole plan period is 964 per annum. The
2018s0255 TDC WCS Phase 1 Scoping v3.0 11plan also makes provision for 25ha of employment land around Burgess Hill; this is based
on an estimated job growth of 543 jobs per year over the plan period.
Table 2.9 Summary of growth in Crawley Borough that could affect shared
infrastructure with Tandridge
WwTW Housing Units Employment (m2) Notes
Committed Allocated Committed Allocated
Felbridge 63 0 0 0 Planning permission
for 1 site of 61
(gross) and 2 small
sites.
Crawley 1269 44 17,259m2 0 Planning permission
for 600 units at
Pease Pottage (also
allocated in District
Plan). Of which 350
will be delivered in
the next five years.
Planning permission
for 544 at A264
Copthorne.
2.6.5 Sevenoaks District Council
Sevenoaks shares Tandridge’s eastern border.
A need of 11.6ha of employment space is stated, and they are still determining how this
will be distributed across the district. An update to their Strategic Housing and Economic
Land Availability Assessment (SHELAA) is being published alongside their draft Local Plan
consultation in summer 2018. No water cycle study has been conducted for this area.
Table 2.10 Summary of growth in Crawley Borough that could affect shared
infrastructure with Tandridge
WwTW Housing Units Employment (m2) Notes
Committed Allocated Committed Allocated
Edenbridge 387 0 0 0
Oxted 0 0 0 0
Lingfield 0 0 0 0
2018s0255 TDC WCS Phase 1 Scoping v3.0 123 Legislative and Policy Framework
3.1 Introduction
The following sections introduce several national, regional and local policies that must be
considered by the LPAs, water companies and developers during the planning stage. Key
extracts from these policies relating to water consumption targets and mitigating the
impacts on the water from the new development are summarised below.
3.2 National Policy
3.2.1 National Planning Policy Framework
The National Planning Policy Framework (NPPF) 10 was published on 27th March 2012, as
part of reforms to make the planning system less complex and more accessible, to protect
the environment and to promote sustainable growth. The NPPF provides guidance to
planning authorities to take account of flood risk and water and wastewater infrastructure
delivery in their Local Plans.
Paragraph 94:
“Local planning authorities should adopt proactive strategies to mitigate and
adapt to climate change, taking full account of flood risk, coastal change and
water supply and demand considerations”
Paragraph 99:
“Local Plans should take account of climate change over the longer term,
including factors such as flood risk, coastal change, water supply and changes to
biodiversity and landscape. New development should be planned to avoid
increased vulnerability to the range of impacts arising from climate change.
When new development is brought forward in areas which are vulnerable, care
should be taken to ensure that risks can be managed through suitable
adaptation measures, including through the planning of green infrastructure.”
Paragraph 100 states:
“Local Plans should be supported by a strategic flood risk assessment and
develop policies to manage flood risk from all sources, taking account of advice
from the Environment Agency and other relevant flood risk management bodies,
such as Lead Local Flood Authorities and Internal Drainage Boards. Local Plans
should apply a sequential, risk-based approach to the location of development to
avoid, where possible, flood risk to people and property and manage any
residual risk, taking account of the impacts of climate change”.
Paragraph 156 states
“Local planning authorities should set out the strategic priorities for the area in
the Local Plan. This should include strategic policies to deliver...the provision of
infrastructure for transport, telecommunications, waste management, water
supply, wastewater, flood risk and coastal changes management, and the
provision of minerals and energy”.
In March 2014, the Planning Practice Guidance was issued by the Department for
Communities and Local Government, with the intention of providing guidance on the
application of the National Planning Policy Framework (NPPF) in England. Of relevance to
this study;
—————————————————————————————————————————————
10 National Planning Policy Framework, Department for Communities and Local Government (2012)
2018s0255 TDC WCS Phase 1 Scoping v3.0 13• Flood Risk and Coastal Change11
• Water Supply, Wastewater and Water Quality12.
• Housing - Optional Technical Standards13.
3.2.2 Planning Practice Guidance: Flood Risk and Coastal Change
Diagram 1 in the Planning Practice Guidance sets out how flood risk should be considered
in the preparation of Local Plans (Figure 3.1). These requirements are addressed principally
in the Council’s Strategic Flood Risk Assessment.
—————————————————————————————————————————————
11 Planning Practice Guidance: Flood Risk and Coastal Change, Department for Communities and Local Government (2014). Accessed
online at: http://planningguidance.planningportal.gov.uk/blog/guidance/flood-risk-and-coastal-change/ on: 09/03/2018.
12 Planning Practice Guidance: Water supply, wastewater and water quality, Department for Communities and Local Government (2014).
Accessed online at: https://www.gov.uk/guidance/water-supply-wastewater-and-water-quality on: 09/03/2018
13 Planning Practice Guidance: Housing - Optional Technical Standards, Department for Communities and Local Government (2014).
Accessed online at: https://www.gov.uk/guidance/housing-optional-technical-standards on: 09/03/2018
2018s0255 TDC WCS Phase 1 Scoping v3.0 14Figure 3.1 Flood Risk and the Preparation of Local Plans14 ————————————————————————————————————————————— 14 Based on Diagram 1 of NPPF Planning Practice Guidance: Flood Risk and Coastal Change (paragraph 004, Reference ID: 7-021- 20140306 2018s0255 TDC WCS Phase 1 Scoping v3.0 15
3.2.3 Planning Practice Guidance: Water Supply, Wastewater and Water Quality
A summary of the specific guidance on how infrastructure, water supply, wastewater and
water quality considerations should be accounted for in both plan-making and planning
applications is summarised below in Figure 3.2.
Plan-making Planning applications
Identification of suitable sites for new or
enhanced infrastructure. Wastewater considerations include:
Infrastructure
Consider whether new development is First presumption is to provide a system of foul
appropriate near to water and wastewater drainage discharging into a public sewer.
infrastructure. Phasing of development and infrastructure.
Phasing new development so that water Circumstances where package sewage treatment
and wastewater infrastructure will be in plants or septic tanks are applicable.
place when needed.
Planning for the necessary water supply would
Water supply
normally be addressed through the Local Plan,
exceptions might include:
Not Specified
Large developments not identified in Local Plans;
Where a Local Plan requires enhanced water
efficiency in new developments.
How to help protect and enhance local
surface water and groundwater in ways Water quality is only likely to be a significant
that allow new development to proceed planning concern when a proposal would:
Water quality
and avoids costly assessment at the Involve physical modifications to a water body;
planning application stage. Indirectly affect water bodies, for example as a
The type or location of new development result of new development such as the
where an assessment of the potential redevelopment of land that may be affected by
impacts on water bodies may be required. contamination etc. or through a lack of adequate
Expectations relating to sustainable infrastructure to deal with wastewater.
drainage systems.
Wastewater
The sufficiency and capacity of If there are concerns arising from a planning
wastewater infrastructure. application about the capacity of wastewater
The circumstances where wastewater infrastructure, applicants will be asked to provide
from new development would not be information about how the proposed development
expected to drain to a public sewer. will be drained and wastewater dealt with.
Water supply and water quality concerns
boundary
concerns
Cross-
often cross local authority boundaries and
No specific guidance (relevant to some
can be best considered on a catchment
developments).
basis. Recommends liaison from the
outset.
Water supply and quality are
Sustainability
considerations in strategic environmental
assessment and sustainability appraisal
SEA and
... sustainability appraisal objectives could
include preventing deterioration of current No specific guidance (should be considered in
water body status, taking climate change applications).
into account and seeking opportunities to
improve water bodies.
Figure 3.2 PPG: Water supply, wastewater and water quality considerations for plan-
making and planning applications
2018s0255 TDC WCS Phase 1 Scoping v3.0 163.2.4 Planning Practice Guidance: Housing – Optional Technical Standards
This guidance, advises planning authorities on how to gather evidence to set optional
requirements, including for water efficiency. It states that “all new homes already have to
meet the mandatory national standard set out in the Building Regulations (of 125
litres/person/day). Where there is a clear local need, local planning authorities can set out
Local Plan policies requiring new dwellings to meet the tighter Building Regulations optional
requirement of 110 litres/person/day. Planning authorities are advised to consult with the
EA and water companies to determine where there is a clear local need, and also to consider
the impact of setting this optional standard on housing viability. A 2014 study15 into the
cost of implementing sustainability measures in housing found that meeting a standard of
110 litres per person per day would cost only £9 for a four-bedroom house.
3.2.5 Building Regulations and Code for Sustainable Homes
The Building Regulations (2010) Part G16 was amended in early 2015 to require that all new
dwellings must ensure that the potential water consumption must not exceed 125
litres/person/day, or 110 litres/person/day where required under planning conditions.
The Code for Sustainable Homes (CfSH) was, from 2007 to March 2015, the Government’s
optional national standard for new housing. It became effective in England in April 2007
and a Code rating for new homes became mandatory in May 2008. The Code included six
levels of water efficiency for new homes seeking to simplify the various building codes that
house builders have to adhere to, the Government withdrew CfSH in March 2015, with the
exception of legacy cases: "where residential developments are legally contracted to apply
a code policy (e.g. affordable housing funded through the National Affordable Housing
Programme 2015 to 2018, or earlier programme), or where planning permission has been
granted subject to a condition stipulating discharge of a code level, and developers are not
appealing the condition or seeking to have it removed or varied".
3.2.6 BREEAM
The Building Research Establishment Environmental Assessment Methodology (BREEAM) is
an internationally recognised method for assessing, rating and certifying the sustainability
of buildings. BREEAM can be used to assess the environmental performance of any type of
building: new and existing. Standard BREEAM schemes exist for assessment of common
domestic and non-domestic building types and less common building types can be assessed
by developing bespoke criteria.
Using independent, licensed assessors, BREEAM assesses criteria covering a range of issues
in categories that evaluate energy and water use, health and wellbeing, pollution, transport,
materials, waste, ecology and management processes. Buildings are rated and certified on
a scale of ‘Pass’, ‘Good’, ‘Very Good’, ‘Excellent’ and ‘Outstanding’.
BREEAM has expanded from its original focus on individual new buildings at the construction
stage to encompass the whole life cycle of buildings from planning to in-use and
refurbishment. The standard is regularly revised to improve sustainability, respond to
industry feedback and support sustainability strategies and commitments. BREEAM
standard can be applied to virtually any building and location, with versions for new
buildings, existing buildings, refurbishment projects and large developments.
TDC has the opportunity to seek BREEAM status for all new, residential and non-residential
buildings. It currently seeks BREEAM “Very Good” through the 2008 Core Strategy17. Whilst
—————————————————————————————————————————————
15 Housing Standards Review: Cost Impacts, Department for Communities and Local Government (2014). Accessed online at:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/353387/021c_Cost_Report_11th_Sept_2014_FINAL.p
df on: 09/03/2018
16 The Building Regulations (2010) Part G - Sanitation, hot water safety and water efficiency, 2015 edition with 2016 amendments. HM
Government (2016). Accessed online at:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/504207/BR_PDF_AD_G_2015_with_2016_amendmen
ts.pdf on: 09/03/2018
17 Tandridge District Core Strategy, Tandridge District Council (2008). Accessed online at:
https://www.tandridge.gov.uk/Portals/0/Documents/Planning%20and%20building/Planning%20strategies%20and%20policies/Current
2018s0255 TDC WCS Phase 1 Scoping v3.0 17BREEAM contains the flexibility to achieve this in a number of ways, a “Very Good” rating
for water resources would typically relate to a 40% improvement over baseline building
water consumption18. As a minimum, a 12.5% improvement must be demonstrated to
obtain BREEAM status. Guidance is provided on how to calculate this. Table 3.1 shows the
BREEAM credits available for percentage improvement over baseline building water
consumption in precipitation zone 1, which covers the whole of the UK.
Table 3.1 BREEAM credits for percentage improvement over baseline water
consumption
BREEAM Percentage
Credits improvement over
baseline water
consumption
1 12.5%
2 25%
3 40%
4 50%
5 55%
Exemplary 65%
3.2.7 Sustainable Drainage Systems (SuDS)
From April 2015, Local Planning Authorities (LPA) have been given the responsibility for
ensuring through the planning system that sustainable drainage is implemented on
developments of 10 or more homes or other forms of major development. Under the new
arrangements, the key policy and standards relating to the application of SuDS to new
developments are:
• The National Planning Policy Framework, which requires that development in
areas already at risk of flooding should give priority to sustainable drainage
systems.
• The House of Commons written statement19 setting out governments intentions
that LPAs should “ensure that sustainable drainage systems for the management
of run-off are put in place, unless demonstrated to be inappropriate” and “clear
arrangements in place for ongoing maintenance over the lifetime of the
development.” In practice, this has been implemented by making Lead Local
Flood Authorities (LLFAs) statutory consultees on the drainage arrangements of
major developments.
• The Defra non-statutory technical standards for sustainable drainage systems 20.
These set out the government’s high-level requirements for managing peak flows
and runoff volumes, flood risk from drainage systems and the structural integrity
and construction of SuDS. This very short document is not a design manual and
makes no reference to the other benefits of SuDS, for example water quality,
habitat and amenity.
• Surrey County Council are the LLFA and play a key role in ensuring that the
proposed drainage schemes for all new developments comply with technical
standards and policies in relation to SuDS.
—————————————————————————————————————————————
%20and%20adopted%20planning%20policies/Core%20strategy/Core-Strategy.pdf on: 09/03/2018
18 BREEAM International New Construction 2016: Technical Manual SD233 2.0, BREEAM (2016). Accessed online at:
https://www.breeam.com/discover/technical-standards/newconstruction/ on: 09/03/2018
19 Sustainable drainage systems: Written statement - HCWS161, UK Government (2014). Accessed online at:
http://www.parliament.uk/business/publications/written-questions-answers-statements/written-statement/Commons/2014-12-
18/HCWS161/ on: 09/03/2018
20 Sustainable Drainage Systems: Non-statutory technical standards for sustainable drainage systems, Defra (2015).
2018s0255 TDC WCS Phase 1 Scoping v3.0 18You can also read
