Addition at the end of the section entitled 'Water Quality and Wastewater' - “Development shall connect to public mains sewer as the first option, and if that is not possible, provide justification for this and why a different option is needed.”

We can support the policy requirement that new residential proposals must demonstrate that a maximum water consumption of 110 litres per person per day.

The District lies within a serious water stressed area (as classified in 2021). The Government’s Written Ministerial Statement dated 1 July 2021 (HCWS140) highlighted the need for water efficient homes and announced the publication during 2022 of a roadmap towards greater water efficiency in new developments, including exploration of revised building regulations. Water efficiency is important not only from a water resource perspective, but also because of the link with water quality and disposal of foul water. There are real benefits in keeping down the capital cost of new water supply and waste water infrastructure, maintaining ecosystems and protecting landscapes. Reducing the amount of water entering waste water treatment works is also a key way of helping to mitigate issues around the capacity of the works and the receiving environment. Water efficiency standards can also help deliver objectives set out in River Basin Management Plans.

We are pleased that our comments at the Regulation 18 consultation regarding wastewater have been incorporated into this policy. The section entitled ‘Water Quality and Wastewater’ could be slightly improved by adding wording to reflect that development should connect to public mains sewer as a first option to ensure that the situation of lots of small private treatment plants does not crop up. We suggest additional wording to the end of the section to say “Development shall connect to public mains sewer as the first option, and if that is not possible, provide justification for this and why a different option is needed.” Connection to mains is preferable as it is more likely that systems will be maintained and improved over time. This also accords with the Planning Practice Guidance for Water supply, wastewater and water quality.

The policy references the Apuldram Position Statement, which we reviewed in July 2022 and concluded that it was still applicable and should continue to restrict development connecting to the Apuldram (Chichester) Wastewater Treatment Works (WwTW) to manage impacts on the Chichester Harbour from the increased use of storm overflow as a result of groundwater infiltration issues. The Thornham Position Statement is also referenced, albeit the issue here is related to infrastructure capacity.

We will raise that Lavant WwTW also has similar groundwater infiltration issues to Apuldram WwTW and as such may not have capacity for further connections in the future. Groundwater infiltration issues are difficult to improve upon and this is a continuing challenge for Southern Water.

Whilst Tangmere WwTW has been upgraded, further upgrades may be necessary in the future to accommodate more development.

We are currently working with the Local Authority and Southern Water to produce a Statement of Common Ground for Wastewater to provide more detail around the wastewater issues in the district. We understand that the Local Authority keep informed about capacity and discuss such matters with appropriate partners.