The Council welcomes the recognition of the Essex Coast RAMS project and acknowledges the identified need to seek financial contributions to mitigate the impact on protected habitats sites of increased recreational disturbance resulting from housing growth. The Council notes that a supplementary planning document is currently being prepared jointly by a collective of authorities, including both Rochford and Brentwood Councils. This supplementary planning document is expected to provide a robust policy mechanism for the collection of these financial contributions. The Council is satisfied that policy NE02 is a sound and legally compliant approach to funding mitigation as part of the Essex Coast RAMS

Replace Policy NE02 A. & B. wording with the following -

Where appropriate, contributions from developments will be secured towards mitigation measures identified in the Essex Recreational Disturbance Avoidance and Mitigation Strategy (RAMS) which will be completed by the time the Local Plan is adopted. Prior to RAMS completion, the authority will seek contributions, where appropriate, from proposed residential development to deliver all measures identified (including strategic measures) through project level HRAs, or otherwise, to mitigate any recreational disturbance impacts in compliance with the Habitat Regulations and Habitats Directive.

3. Effective

Natural England advice is that ALL residential development within the RAMS Zone of Influence will need to provide mitigation and this will trigger a proportionate financial contribution.

The Essex Rams Steering Group agreed the following action at its 5th February 2019 meeting -
ALL to endeavour to use the policy text in Chelmsford's emerging Local Plan for the RAMS so that there is consistency across all LPAs involved in the Essex Coast RAMS

The wording was agreed in response to issues raised by Natural England (PS2078) in response to Chelmsford Draft Local Plan and was included in their Schedule of Additional Changes - June 2018.

Dear Sir/Madam,
Thank you for consulting Thames Water on the above document. Thames Water is the statutory sewerage undertaker for part of the Borough and is hence a "specific consultation body" in accordance with the Town & Country Planning (Local Development) Regulations 2012.
Planning Policies
Thames Water support the proposed policies within the Pre-submission Local Plan. Notwithstanding this it is suggested that minor modifications are made to the text within Policies SP01 and SP04 in order to ensure that the policies are effective in relation to ensuring development is delivered alongside any necessary sewerage infrastructure reinforcement works required to support it. The proposed modifications are set out in the attached response forms. In relation to Policy NE02 the requirement for engagement with sewerage providers is welcomed. To assist with promoting early engagement it would be beneficial if a link to Thames Waters pre-application service could be provided on the Councils website. Details regarding Thames Waters pre-application service can be found at: www.thameswater.co.uk/preplanning

Site Specific Comments
We have undertaken a high level review of the proposed site allocations within the Thames Water catchment and have appended comments in relation to wastewater infrastructure issues for these sites in table below.
R04 & R05 - Ford Headquarters and Council Depot, Warley: The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and
how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application. R06 - Land off Nags Head Lane, Brentwood The wastewater network capacity in this area may be unable to support the demand
anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application.
R07 - Sow & Grow Nursery, Ongar Road, Pilgrims Hatch
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ
R08 - Land adjacent to Camel, Mascalls Lane, Warley
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ. We do not envisage network infrastructure concerns regarding wastewater infrastructure capability in relation to this site on a basis that it won't be any surface water connection into a public foul sewer system. Connection of surface water into a public foul sewer system reduces sewer capacity and has the potential to cause flooding to existing customers. Drainage hierarchy to be followed in addressing surface water.
R09 - Land west of Warley Hill, Pastoral Way, Warley
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ
Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R10 - Brentwood railway station car park St James Road, Brentwood
The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application. A significant assets run beneath the site. We would seek protection of these assets and may require several wayleaves /easements. Drainage hierarchy to be followed in addressing surface water. As this is brown field site, we expect significant reduction in surface water runoff.
R11 - Westbury Road Car Park, Westbury Road, Brentwood
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Drainage hierarchy to be followed in addressing surface water. As this is a
brown field site, we expect significant reduction in surface water runoff.
R12 - Land at Hunter House, Western Road, Brentwood (Reviewed Jan18)
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Surface water to be addressed according to the Drainage hierarchy. This being a brownfield site we expect a significant reduction in surface water runoff.
R13 Chatham Way/Crown Street Car Park, Brentwood (Reviewed Jan18)
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing.Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R14 - WILLIAM HUNTER WAY, CAR
PARK SITE, BRENTWOOD
The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead
of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be
submitted with the planning application. Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R15 - Wates Way Industrial Estate,
Ongar Road, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding water supply network or water
treatment infrastructure capacity in relation
to this site/s. It is recommended that the
Developer and the Local Planning Authority
liaise with Thames Water at the earliest
opportunity to advise of the developments
phasing. Please contact Thames Water
Development Planning, either by email
Devcon.team@thameswater.co.uk tel:
02035779998 or in writing Thames Water
Utilities Ltd, Maple Lodge STW, Denham
Way, Rickmansworth, Hertfordshire, WD3
9SQ
Drainage hierarchy to be followed in
addressing surface water. As this is a
brown field site, we expect significant
reduction in surface water runoff.
R16 & R17- Land off Doddinghurst Road, either side of A12, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater network or
wastewater treatment infrastructure
capability in relation to this site/s. It is
recommended that the Developer and the
Local Planning Authority liaise with Thames
Water at the earliest opportunity to advise of
the developments phasing. Please contact
Thames Water Development Planning,
either by email
Devcon.team@thameswater.co.uk tel:
02035779998 or in writing Thames Water
Utilities Ltd, Maple Lodge STW, Denham
Way, Rickmansworth, Hertfordshire, WD3
9SQ
R19- Land At Priests Lane, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Please note that the above comments
relate to the sewerage network within the
Thames Water supply area only. It is
recommended that Anglian Water are also
consulted for their comments in relation to
this development proposal. Drainage
hierarchy to be followed in addressing
surface water.
R23 - Brizes Corner Field, Blackmore
Road, Kelvedon Hatch
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Drainage hierarchy to be followed in
addressing surface water. Please note that
the above comments relate to the sewerage
network within the Thames Water supply
area only. It is recommended that Anglian
Water are also consulted for their
comments in relation to this development
proposal.
R24 - Land off Stocks Lane, Kelvedon Hatch
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Drainage hierarchy to be followed in
addressing surface water. Please note that
the above comments relate to the sewerage
network within the Thames Water supply
area only. It is recommended that Anglian
Water are also consulted for their
comments in relation to this development
proposal.

POLICY SP04
In relation to wastewater infrastructure it will be essential that new development is aligned with any
necessary upgrades required to ensure that the development would not overload the existing
sewerage network. Thames Water therefore support the content of Policy NE2 parts D and E and
encourage developers proposing developments to engage with them at an early stage to discuss the
wastewater infrastructure requirements for development.
The proposed policy ensures that the Local Plan is consistent with Paragraphs 20 and 41 of the NPPF.
Alongside the proposed amended text for Policy SP04, the policy will help ensure the effective
delivery of any sewerage network reinforcement works necessary to support development.

POLICY SP04
In relation to wastewater infrastructure it will be essential that new development is aligned with any
necessary upgrades required to ensure that the development would not overload the existing
sewerage network.
Thames Water support the policy in principle. However, it should be noted that new sewerage
infrastructure is delivered by the sewerage undertaker and funded through the infrastructure charge
for new developments connecting to the sewerage network. It is not therefore possible for any
necessary upgrades to be secured through CIL or S106 contributions. In order to ensure that any
necessary sewerage infrastructure reinforcement works required to support a development are
delivered ahead of the occupation of development it may be necessary for planning conditions to be
used to ensure that a development or phase of development is not occupied until the required
upgrade has been delivered. To help ensure this Policy SP04 should make reference to the use of
planning conditions as a mechanism to ensure the delivery of infrastructure alongside S106
agreements and CIL.

To address the above concern Part B of Policy SP04 could be amended to incorporate the following
wording:
"c. off-site capacity improvement works (secured through appropriate planning conditions or
agreements)"
The proposed change would ensure that planning conditions can be used to secure infrastructure
improvements necessary to support development alongside S106 agreements and CIL thereby
ensuring that the policy is effective and the Local Plan is sound.

POLICY SP01:
Thames Water support the aim of Policy SP01 (D) in relation to ensuring development does not result
in unacceptable impacts on amenity. However, as worded the policy would only be effective in
ensuring that development itself has no unacceptable impact on amenity. Consideration is also
required to be given to whether the location of proposed development is appropriate taking into
account existing sources of noise, odour and vibration to ensure that the amenity of future occupiers
of development will not be adversely affected by such issues. Where development would be affected
by an existing source of noise, odour or vibration development should only be allowed where it is
demonstrated that suitable mitigation measures can be put in place and it has been demonstrated
how these will be delivered. This would be required in order to ensure that the policy is consistent
with Paragraph 182 of the NPPF 2019.
To address the above concern it is considered that Part D(e) of Policy SP01 could be revised to read as
follows:
"e. has no unacceptable effect on health, the environment or amenity due to the release of pollutants
(such as light, noise pollution, vibration, odour, smoke, ash, dust and grit) to land, water or air, and
where the amenity of future occupiers would not be adversely impacted by existing sources of such
pollutants unless suitable mitigation measures are proposed and secured;"
The additional wording would ensure that development is not located where the amenity of future
residents would be affected by existing sources of polluntants unless suitable mitigation is provided.
This would ensure that the policy is effective and consistent with the NPPF and therefore sound.

POLICY BE18: GREEN AND BLUE INFRASTRUCTURE
Policy is in accordance with national planning guidance and the Habitats Regulations through seeking to protect, conserve and enhance the natural environment.
POLICY NE01: PROTECTING AND ENHANCING THE NATURAL ENVIRONMENT
Policy is in accordance with national planning guidance and the Habitats Regulations through seeking to protect, conserve and enhance the natural environment.
POLICY NE02: RECREATIONAL DISTURBANCE AVOIDANCE AND MITIGATION
STRATEGY (RAMS)
Policy ensures any residential development that is likely to affect the integrity of those European Sites identified under the Essex RAMS, or Epping Forest SAC will
be required to either contribute towards mitigation measures identified in the RAMS or, in exceptional circumstances, identify and implement bespoke mitigation measures to ensure compliance with the Habitat Regulations.

POLICY R01 (I): DUNTON HILLS GARDEN VILLAGE STRATEGIC ALLOCATION
Policy incorporates measures to avoid significant adverse impacts on designated sites including those identified under Essex RAMS, arising from this new development (subject to a well-designed masterplan being produced which includes all relevant and necessary measures).