Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Support

Representation ID: 498

Received: 30/01/2026

Respondent: South West Water (Statutory / General Consultation Body)

These representations have been prepared by South West Water Limited [SWW] in response to the Regulation 18 Public Consultation on the Draft Torbay Local Plan. The comments above have been written from SWWs perspective as Statutory Water and Sewerage Undertaker for the Torbay area. As such, the representations set out above comment only on matters relating to the provision of water and sewerage services, including potential impacts on Water and wastewater infrastructure network and treatment.

Support

Representation ID: 2994

Received: 30/01/2026

Respondent: South West Water (Statutory / General Consultation Body)

These representations have been prepared by South West Water Limited [SWW] in response to the Regulation 18 Public Consultation on the Draft Torbay Local Plan. The comments below have been written from SWWs perspective as Statutory Water and Sewerage Undertaker for the Torbay area. As such, the representations set out below comment only on matters relating to the provision of water and sewerage services, including potential impacts on operational infrastructure.

Policy

Water Efficiency
The South West region has among the highest water consumption rates in the country, with significant shifts in average consumption behaviours exacerbated by sharp increases in consumption during peak tourism seasons. To further sustainable water consumption, the Undertaker would fully support the Torbay Local Plan in including enhanced water efficiency measures within draft policies, such as: a requirement for all dwellings to achieve an estimated maximum water consumption of 110 litres/person/day; in line with Building Regulations Part G Optional Requirement G2.
Similarly, SWWL would support the inclusion of a specified standard for water efficiency within this policy for proposals relating to non-residential development. An example policy imposing such a requirement can be found within the Draft Policy 96 of the Wiltshire Council Draft Local Plan (which was submitted for Examination in November 2024). The wording proposed within this draft policy specifies the need for non-residential development to achieve a score of three credits within the Water (Wat 01 Water Consumption) issue category of the BREEAM New Construction Standard. Though primarily rural in character, implementing such policy will promote sustainability for all relevant development across the proposed plan period.
SWWL would support the inclusion of policy to encourage rainwater harvesting. Harvesting techniques, such as water butts, can help reduce strain on the water supply as this alternative water source can be used for non-potable uses – including the likes of gardening uses – rather than relying on potable, treated drinking water from the public supply. SWWL would encourage the inclusion of specific policy wording requiring development proposals to incorporate water efficiency and reuse measures such as rainwater harvesting, subject to viability.

Sustainable Urban Drainage Systems (SuDs)
SWWL supports the inclusion of a policy for the purpose of minimising surface water run-off by encouraging the inclusion of SuDs. With continuing trends of Climate Change resulting in hotter, drier summers and wetter, milder winters (IPPC, August 2021), impacts – like the threat of exacerbated drought and flood cycles – pose significant risk to our environments. During periods of drought the soil can become compacted, and when the rains arrive the soil cannot absorb the excess rainfall at a sufficient rate; increasing the volumes of surface water run-off, carrying soil and other surface particulates with it. The implementation of natural SuDs within the proposed policy, creates increased opportunity for maximising the use of rainwater on land for a longer period than direct sewer disposal. The utility of infiltration techniques like swales, tree planters, rain gardens, ponds and wetlands can provide a broad range of benefits, including:

- Enabling slow absorption prior to drought events of surface waters into the ground, allowing sufficient saturation into the soil substrata to provide greater drought resiliency;
- Enabling slow absorption, post drought events, of surface waters into the ground, promoting recovery of the moisture content of the soil.
- Reduction of surface water run-off, reducing sediment and other particulates entering sewers and surface water bodies.

Natural SuDs aim to mimic the way rainfall drains in the natural system to manage the quantity and quality of surface water runoff from developed sites, while also contributing to amenity and biodiversity. By enforcing the use of SuDs and rainwater harvesting techniques within all local development, the burden placed upon the existing drainage infrastructure can be limited, and potential betterment secured in combination with SWWLs ongoing initiatives. Slowing the rate of surface water runoff via water retention techniques supports the reduction of surface water ingress into the public sewerage network, as well as enabling development to maximise sustainability, biodiversity and water quality benefits.
SWWL would support Torbay Local Plan in building on the requirements in placing an increased requirement on development to incorporate rainwater harvesting measures and adhere to the surface water disposal hierarchy, the base standard of which being set within Planning Practice Guidance (Para ID: 7-056-20220825). A good example of where policy incorporating this has been adopted can be found in the Salford Local Plan Policy WA5 which states:

“Surface water shall be managed in line with the following hierarchy (highest priority first) recognising that a combination of measures from different levels in the hierarchy may be required to satisfactorily deal with all surface water:

1.Infiltration to vegetation
2.Store rainwater for later use on-site
3.Infiltration (into the ground)
4.Discharge to a surface water body such as a pond
5.Discharge to a watercourse
6.Discharge to a surface water sewer or highway drain
Only in exceptional circumstances, where evidence is provided that levels 1-6 above are not possible, discharge into the combined sewer network, either directly or indirectly”.


Infrastructure

Water Network

Within the Torbay local plan 59 sites can be accommodated within the existing water supply network and infrastructure. The 59 sites identified are considered to be likely to have a low impact and are not expected to require significant upgrades to the water distribution network from the Undertaker’s high-level assessment. As the allocations progress, if it is determined that any network reinforcements are required, this would be funded through the Infrastructure Charge that SWWL imposes on developers.

Two sites (H3T.1 and H3T.2) of the sites within the Torbay local plan are considered to pose a medium impact on the existing water distribution network; as based upon the size or location of the development, these proposed sites are likely to require some upgrades to the water distribution network to be accommodated. Further assessment would be required relating to specific proposed details to assess the particular scale and specifics of required upgrades.





Water Treatment

SWW are tasked with planning the future of our region’s water resources to ensure it can maintain essential supplies and protect the environment in times of drought, and as a result water companies are required to prepare and maintain a Water Resources Management Plan (WRMP) on a five yearly cycle.

The WRMP sets out how SWW plan to manage supply and demand for the next 25 years. It examines strategic issues that influence demand for water and water availability. It also sets out how SWW intend to maintain the balance between water supply and demand to ensure customers receive a continued reliable supply and to protect the environment.

Torbay is within the Roadford Water Resource Zone and SWW are aiming to reduce leakage and overall demand so that there is less pressure on our resources. In our Roadford zone we will invest in additional raw water transfer capacity in 2035/36 to offset an Environmental Destination abstraction reduction of 16.99 ML/d on the River Dart.

There will be sufficient water resource available to supply the developments detailed in the Torbay consultation.

This is a link to the Water Resources Management Plan published by South SWW: -
Water resources management plan | South West Water.


Wastewater Network

Within the Torbay local plan 57 sites can have their foul flows accommodated within the existing wastewater network and infrastructure. The 57 sites identified are considered to be likely to have a low impact and are not expected to require significant upgrades to the wastewater network from the Undertaker’s high-level assessment. As the allocations progress, if it is determined that any network upgrades are required, this would be funded through the Infrastructure Charge that SWWL imposes on developers.

Four of the sites (H2P.4, H2P.3, H3P.3 and H2T.1) within the Torbay local plan are considered to pose a medium impact on the existing wastewater network; as based upon the size or location of the development, these proposed sites are likely to require some upgrades to the wastewater network to accommodate their foul flows. Further assessment would be required relating to specific proposed details to assess the particular scale and specifics of required upgrades.

 
Wastewater Treatment

Brokenbury Quarry Sewage Treatment Works

The foul flows of the sites included within the Torbay Local Plan would be treated at the Brokenbury Quarry sewage treatment works. It is planned to invest in the sludge treatment process at Brokenbury Quarry STW within the next ten years. However, the existing works do have sufficient treatment capacity to deal with the foul flows that would be generated by all the sites identified within the Torbay local plan.

Support

Representation ID: 3003

Received: 30/01/2026

Respondent: South West Water (Statutory / General Consultation Body)

These representations have been prepared by South West Water Limited [SWW] in response to the Regulation 18 Public Consultation on the Draft Torbay Local Plan. The comments below have been written from SWWs perspective as Statutory Water and Sewerage Undertaker for the Torbay area. As such, the representations set out below comment only on matters relating to the provision of water and sewerage services, including potential impacts on operational infrastructure.

Policy

Water Efficiency
The South West region has among the highest water consumption rates in the country, with significant shifts in average consumption behaviours exacerbated by sharp increases in consumption during peak tourism seasons. To further sustainable water consumption, the Undertaker would fully support the Torbay Local Plan in including enhanced water efficiency measures within draft policies, such as: a requirement for all dwellings to achieve an estimated maximum water consumption of 110 litres/person/day; in line with Building Regulations Part G Optional Requirement G2.
Similarly, SWWL would support the inclusion of a specified standard for water efficiency within this policy for proposals relating to non-residential development. An example policy imposing such a requirement can be found within the Draft Policy 96 of the Wiltshire Council Draft Local Plan (which was submitted for Examination in November 2024). The wording proposed within this draft policy specifies the need for non-residential development to achieve a score of three credits within the Water (Wat 01 Water Consumption) issue category of the BREEAM New Construction Standard. Though primarily rural in character, implementing such policy will promote sustainability for all relevant development across the proposed plan period.
SWWL would support the inclusion of policy to encourage rainwater harvesting. Harvesting techniques, such as water butts, can help reduce strain on the water supply as this alternative water source can be used for non-potable uses – including the likes of gardening uses – rather than relying on potable, treated drinking water from the public supply. SWWL would encourage the inclusion of specific policy wording requiring development proposals to incorporate water efficiency and reuse measures such as rainwater harvesting, subject to viability.

Sustainable Urban Drainage Systems (SuDs)
SWWL supports the inclusion of a policy for the purpose of minimising surface water run-off by encouraging the inclusion of SuDs. With continuing trends of Climate Change resulting in hotter, drier summers and wetter, milder winters (IPPC, August 2021), impacts – like the threat of exacerbated drought and flood cycles – pose significant risk to our environments. During periods of drought the soil can become compacted, and when the rains arrive the soil cannot absorb the excess rainfall at a sufficient rate; increasing the volumes of surface water run-off, carrying soil and other surface particulates with it. The implementation of natural SuDs within the proposed policy, creates increased opportunity for maximising the use of rainwater on land for a longer period than direct sewer disposal. The utility of infiltration techniques like swales, tree planters, rain gardens, ponds and wetlands can provide a broad range of benefits, including:

- Enabling slow absorption prior to drought events of surface waters into the ground, allowing sufficient saturation into the soil substrata to provide greater drought resiliency;
- Enabling slow absorption, post drought events, of surface waters into the ground, promoting recovery of the moisture content of the soil.
- Reduction of surface water run-off, reducing sediment and other particulates entering sewers and surface water bodies.

Natural SuDs aim to mimic the way rainfall drains in the natural system to manage the quantity and quality of surface water runoff from developed sites, while also contributing to amenity and biodiversity. By enforcing the use of SuDs and rainwater harvesting techniques within all local development, the burden placed upon the existing drainage infrastructure can be limited, and potential betterment secured in combination with SWWLs ongoing initiatives. Slowing the rate of surface water runoff via water retention techniques supports the reduction of surface water ingress into the public sewerage network, as well as enabling development to maximise sustainability, biodiversity and water quality benefits.
SWWL would support Torbay Local Plan in building on the requirements in placing an increased requirement on development to incorporate rainwater harvesting measures and adhere to the surface water disposal hierarchy, the base standard of which being set within Planning Practice Guidance (Para ID: 7-056-20220825). A good example of where policy incorporating this has been adopted can be found in the Salford Local Plan Policy WA5 which states:

“Surface water shall be managed in line with the following hierarchy (highest priority first) recognising that a combination of measures from different levels in the hierarchy may be required to satisfactorily deal with all surface water:

1.Infiltration to vegetation
2.Store rainwater for later use on-site
3.Infiltration (into the ground)
4.Discharge to a surface water body such as a pond
5.Discharge to a watercourse
6.Discharge to a surface water sewer or highway drain
Only in exceptional circumstances, where evidence is provided that levels 1-6 above are not possible, discharge into the combined sewer network, either directly or indirectly”.


Infrastructure

Water Network

Within the Torbay local plan 59 sites can be accommodated within the existing water supply network and infrastructure. The 59 sites identified are considered to be likely to have a low impact and are not expected to require significant upgrades to the water distribution network from the Undertaker’s high-level assessment. As the allocations progress, if it is determined that any network reinforcements are required, this would be funded through the Infrastructure Charge that SWWL imposes on developers.

Two sites (H3T.1 and H3T.2) of the sites within the Torbay local plan are considered to pose a medium impact on the existing water distribution network; as based upon the size or location of the development, these proposed sites are likely to require some upgrades to the water distribution network to be accommodated. Further assessment would be required relating to specific proposed details to assess the particular scale and specifics of required upgrades.





Water Treatment

SWW are tasked with planning the future of our region’s water resources to ensure it can maintain essential supplies and protect the environment in times of drought, and as a result water companies are required to prepare and maintain a Water Resources Management Plan (WRMP) on a five yearly cycle.

The WRMP sets out how SWW plan to manage supply and demand for the next 25 years. It examines strategic issues that influence demand for water and water availability. It also sets out how SWW intend to maintain the balance between water supply and demand to ensure customers receive a continued reliable supply and to protect the environment.

Torbay is within the Roadford Water Resource Zone and SWW are aiming to reduce leakage and overall demand so that there is less pressure on our resources. In our Roadford zone we will invest in additional raw water transfer capacity in 2035/36 to offset an Environmental Destination abstraction reduction of 16.99 ML/d on the River Dart.

There will be sufficient water resource available to supply the developments detailed in the Torbay consultation.

This is a link to the Water Resources Management Plan published by South SWW: -
Water resources management plan | South West Water.


Wastewater Network

Within the Torbay local plan 57 sites can have their foul flows accommodated within the existing wastewater network and infrastructure. The 57 sites identified are considered to be likely to have a low impact and are not expected to require significant upgrades to the wastewater network from the Undertaker’s high-level assessment. As the allocations progress, if it is determined that any network upgrades are required, this would be funded through the Infrastructure Charge that SWWL imposes on developers.

Four of the sites (H2P.4, H2P.3, H3P.3 and H2T.1) within the Torbay local plan are considered to pose a medium impact on the existing wastewater network; as based upon the size or location of the development, these proposed sites are likely to require some upgrades to the wastewater network to accommodate their foul flows. Further assessment would be required relating to specific proposed details to assess the particular scale and specifics of required upgrades.

 
Wastewater Treatment

Brokenbury Quarry Sewage Treatment Works

The foul flows of the sites included within the Torbay Local Plan would be treated at the Brokenbury Quarry sewage treatment works. It is planned to invest in the sludge treatment process at Brokenbury Quarry STW within the next ten years. However, the existing works do have sufficient treatment capacity to deal with the foul flows that would be generated by all the sites identified within the Torbay local plan.

Support

Representation ID: 3004

Received: 30/01/2026

Respondent: South West Water (Statutory / General Consultation Body)

These representations have been prepared by South West Water Limited [SWW] in response to the Regulation 18 Public Consultation on the Draft Torbay Local Plan. The comments below have been written from SWWs perspective as Statutory Water and Sewerage Undertaker for the Torbay area. As such, the representations set out below comment only on matters relating to the provision of water and sewerage services, including potential impacts on operational infrastructure.

Policy

Water Efficiency
The South West region has among the highest water consumption rates in the country, with significant shifts in average consumption behaviours exacerbated by sharp increases in consumption during peak tourism seasons. To further sustainable water consumption, the Undertaker would fully support the Torbay Local Plan in including enhanced water efficiency measures within draft policies, such as: a requirement for all dwellings to achieve an estimated maximum water consumption of 110 litres/person/day; in line with Building Regulations Part G Optional Requirement G2.
Similarly, SWWL would support the inclusion of a specified standard for water efficiency within this policy for proposals relating to non-residential development. An example policy imposing such a requirement can be found within the Draft Policy 96 of the Wiltshire Council Draft Local Plan (which was submitted for Examination in November 2024). The wording proposed within this draft policy specifies the need for non-residential development to achieve a score of three credits within the Water (Wat 01 Water Consumption) issue category of the BREEAM New Construction Standard. Though primarily rural in character, implementing such policy will promote sustainability for all relevant development across the proposed plan period.
SWWL would support the inclusion of policy to encourage rainwater harvesting. Harvesting techniques, such as water butts, can help reduce strain on the water supply as this alternative water source can be used for non-potable uses – including the likes of gardening uses – rather than relying on potable, treated drinking water from the public supply. SWWL would encourage the inclusion of specific policy wording requiring development proposals to incorporate water efficiency and reuse measures such as rainwater harvesting, subject to viability.

Sustainable Urban Drainage Systems (SuDs)
SWWL supports the inclusion of a policy for the purpose of minimising surface water run-off by encouraging the inclusion of SuDs. With continuing trends of Climate Change resulting in hotter, drier summers and wetter, milder winters (IPPC, August 2021), impacts – like the threat of exacerbated drought and flood cycles – pose significant risk to our environments. During periods of drought the soil can become compacted, and when the rains arrive the soil cannot absorb the excess rainfall at a sufficient rate; increasing the volumes of surface water run-off, carrying soil and other surface particulates with it. The implementation of natural SuDs within the proposed policy, creates increased opportunity for maximising the use of rainwater on land for a longer period than direct sewer disposal. The utility of infiltration techniques like swales, tree planters, rain gardens, ponds and wetlands can provide a broad range of benefits, including:

- Enabling slow absorption prior to drought events of surface waters into the ground, allowing sufficient saturation into the soil substrata to provide greater drought resiliency;
- Enabling slow absorption, post drought events, of surface waters into the ground, promoting recovery of the moisture content of the soil.
- Reduction of surface water run-off, reducing sediment and other particulates entering sewers and surface water bodies.

Natural SuDs aim to mimic the way rainfall drains in the natural system to manage the quantity and quality of surface water runoff from developed sites, while also contributing to amenity and biodiversity. By enforcing the use of SuDs and rainwater harvesting techniques within all local development, the burden placed upon the existing drainage infrastructure can be limited, and potential betterment secured in combination with SWWLs ongoing initiatives. Slowing the rate of surface water runoff via water retention techniques supports the reduction of surface water ingress into the public sewerage network, as well as enabling development to maximise sustainability, biodiversity and water quality benefits.
SWWL would support Torbay Local Plan in building on the requirements in placing an increased requirement on development to incorporate rainwater harvesting measures and adhere to the surface water disposal hierarchy, the base standard of which being set within Planning Practice Guidance (Para ID: 7-056-20220825). A good example of where policy incorporating this has been adopted can be found in the Salford Local Plan Policy WA5 which states:

“Surface water shall be managed in line with the following hierarchy (highest priority first) recognising that a combination of measures from different levels in the hierarchy may be required to satisfactorily deal with all surface water:

1.Infiltration to vegetation
2.Store rainwater for later use on-site
3.Infiltration (into the ground)
4.Discharge to a surface water body such as a pond
5.Discharge to a watercourse
6.Discharge to a surface water sewer or highway drain
Only in exceptional circumstances, where evidence is provided that levels 1-6 above are not possible, discharge into the combined sewer network, either directly or indirectly”.


Infrastructure

Water Network

Within the Torbay local plan 59 sites can be accommodated within the existing water supply network and infrastructure. The 59 sites identified are considered to be likely to have a low impact and are not expected to require significant upgrades to the water distribution network from the Undertaker’s high-level assessment. As the allocations progress, if it is determined that any network reinforcements are required, this would be funded through the Infrastructure Charge that SWWL imposes on developers.

Two sites (H3T.1 and H3T.2) of the sites within the Torbay local plan are considered to pose a medium impact on the existing water distribution network; as based upon the size or location of the development, these proposed sites are likely to require some upgrades to the water distribution network to be accommodated. Further assessment would be required relating to specific proposed details to assess the particular scale and specifics of required upgrades.





Water Treatment

SWW are tasked with planning the future of our region’s water resources to ensure it can maintain essential supplies and protect the environment in times of drought, and as a result water companies are required to prepare and maintain a Water Resources Management Plan (WRMP) on a five yearly cycle.

The WRMP sets out how SWW plan to manage supply and demand for the next 25 years. It examines strategic issues that influence demand for water and water availability. It also sets out how SWW intend to maintain the balance between water supply and demand to ensure customers receive a continued reliable supply and to protect the environment.

Torbay is within the Roadford Water Resource Zone and SWW are aiming to reduce leakage and overall demand so that there is less pressure on our resources. In our Roadford zone we will invest in additional raw water transfer capacity in 2035/36 to offset an Environmental Destination abstraction reduction of 16.99 ML/d on the River Dart.

There will be sufficient water resource available to supply the developments detailed in the Torbay consultation.

This is a link to the Water Resources Management Plan published by South SWW: -
Water resources management plan | South West Water.


Wastewater Network

Within the Torbay local plan 57 sites can have their foul flows accommodated within the existing wastewater network and infrastructure. The 57 sites identified are considered to be likely to have a low impact and are not expected to require significant upgrades to the wastewater network from the Undertaker’s high-level assessment. As the allocations progress, if it is determined that any network upgrades are required, this would be funded through the Infrastructure Charge that SWWL imposes on developers.

Four of the sites (H2P.4, H2P.3, H3P.3 and H2T.1) within the Torbay local plan are considered to pose a medium impact on the existing wastewater network; as based upon the size or location of the development, these proposed sites are likely to require some upgrades to the wastewater network to accommodate their foul flows. Further assessment would be required relating to specific proposed details to assess the particular scale and specifics of required upgrades.

 
Wastewater Treatment

Brokenbury Quarry Sewage Treatment Works

The foul flows of the sites included within the Torbay Local Plan would be treated at the Brokenbury Quarry sewage treatment works. It is planned to invest in the sludge treatment process at Brokenbury Quarry STW within the next ten years. However, the existing works do have sufficient treatment capacity to deal with the foul flows that would be generated by all the sites identified within the Torbay local plan.

Support

Representation ID: 3005

Received: 30/01/2026

Respondent: South West Water (Statutory / General Consultation Body)

These representations have been prepared by South West Water Limited [SWW] in response to the Regulation 18 Public Consultation on the Draft Torbay Local Plan. The comments below have been written from SWWs perspective as Statutory Water and Sewerage Undertaker for the Torbay area. As such, the representations set out below comment only on matters relating to the provision of water and sewerage services, including potential impacts on operational infrastructure.

Policy

Water Efficiency
The South West region has among the highest water consumption rates in the country, with significant shifts in average consumption behaviours exacerbated by sharp increases in consumption during peak tourism seasons. To further sustainable water consumption, the Undertaker would fully support the Torbay Local Plan in including enhanced water efficiency measures within draft policies, such as: a requirement for all dwellings to achieve an estimated maximum water consumption of 110 litres/person/day; in line with Building Regulations Part G Optional Requirement G2.

Similarly, SWWL would support the inclusion of a specified standard for water efficiency within this policy for proposals relating to non-residential development. An example policy imposing such a requirement can be found within the Draft Policy 96 of the Wiltshire Council Draft Local Plan (which was submitted for Examination in November 2024). The wording proposed within this draft policy specifies the need for non-residential development to achieve a score of three credits within the Water (Wat 01 Water Consumption) issue category of the BREEAM New Construction Standard. Though primarily rural in character, implementing such policy will promote sustainability for all relevant development across the proposed plan period.

SWWL would support the inclusion of policy to encourage rainwater harvesting. Harvesting techniques, such as water butts, can help reduce strain on the water supply as this alternative water source can be used for non-potable uses – including the likes of gardening uses – rather than relying on potable, treated drinking water from the public supply. SWWL would encourage the inclusion of specific policy wording requiring development proposals to incorporate water efficiency and reuse measures such as rainwater harvesting, subject to viability.

Sustainable Urban Drainage Systems (SuDs)
SWWL supports the inclusion of a policy for the purpose of minimising surface water run-off by encouraging the inclusion of SuDs. With continuing trends of Climate Change resulting in hotter, drier summers and wetter, milder winters (IPPC, August 2021), impacts – like the threat of exacerbated drought and flood cycles – pose significant risk to our environments. During periods of drought the soil can become compacted, and when the rains arrive the soil cannot absorb the excess rainfall at a sufficient rate; increasing the volumes of surface water run-off, carrying soil and other surface particulates with it. The implementation of natural SuDs within the proposed policy, creates increased opportunity for maximising the use of rainwater on land for a longer period than direct sewer disposal. The utility of infiltration techniques like swales, tree planters, rain gardens, ponds and wetlands can provide a broad range of benefits, including:

- Enabling slow absorption prior to drought events of surface waters into the ground, allowing sufficient saturation into the soil substrata to provide greater drought resiliency;
- Enabling slow absorption, post drought events, of surface waters into the ground, promoting recovery of the moisture content of the soil.
- Reduction of surface water run-off, reducing sediment and other particulates entering sewers and surface water bodies.

Natural SuDs aim to mimic the way rainfall drains in the natural system to manage the quantity and quality of surface water runoff from developed sites, while also contributing to amenity and biodiversity. By enforcing the use of SuDs and rainwater harvesting techniques within all local development, the burden placed upon the existing drainage infrastructure can be limited, and potential betterment secured in combination with SWWLs ongoing initiatives. Slowing the rate of surface water runoff via water retention techniques supports the reduction of surface water ingress into the public sewerage network, as well as enabling development to maximise sustainability, biodiversity and water quality benefits.
SWWL would support Torbay Local Plan in building on the requirements in placing an increased requirement on development to incorporate rainwater harvesting measures and adhere to the surface water disposal hierarchy, the base standard of which being set within Planning Practice Guidance (Para ID: 7-056-20220825). A good example of where policy incorporating this has been adopted can be found in the Salford Local Plan Policy WA5 which states:

“Surface water shall be managed in line with the following hierarchy (highest priority first) recognising that a combination of measures from different levels in the hierarchy may be required to satisfactorily deal with all surface water:

1.Infiltration to vegetation
2.Store rainwater for later use on-site
3.Infiltration (into the ground)
4.Discharge to a surface water body such as a pond
5.Discharge to a watercourse
6.Discharge to a surface water sewer or highway drain
Only in exceptional circumstances, where evidence is provided that levels 1-6 above are not possible, discharge into the combined sewer network, either directly or indirectly”.


Infrastructure

Water Network

Within the Torbay local plan 59 sites can be accommodated within the existing water supply network and infrastructure. The 59 sites identified are considered to be likely to have a low impact and are not expected to require significant upgrades to the water distribution network from the Undertaker’s high-level assessment. As the allocations progress, if it is determined that any network reinforcements are required, this would be funded through the Infrastructure Charge that SWWL imposes on developers.

Two sites (H3T.1 and H3T.2) of the sites within the Torbay local plan are considered to pose a medium impact on the existing water distribution network; as based upon the size or location of the development, these proposed sites are likely to require some upgrades to the water distribution network to be accommodated. Further assessment would be required relating to specific proposed details to assess the particular scale and specifics of required upgrades.





Water Treatment

SWW are tasked with planning the future of our region’s water resources to ensure it can maintain essential supplies and protect the environment in times of drought, and as a result water companies are required to prepare and maintain a Water Resources Management Plan (WRMP) on a five yearly cycle.

The WRMP sets out how SWW plan to manage supply and demand for the next 25 years. It examines strategic issues that influence demand for water and water availability. It also sets out how SWW intend to maintain the balance between water supply and demand to ensure customers receive a continued reliable supply and to protect the environment.

Torbay is within the Roadford Water Resource Zone and SWW are aiming to reduce leakage and overall demand so that there is less pressure on our resources. In our Roadford zone we will invest in additional raw water transfer capacity in 2035/36 to offset an Environmental Destination abstraction reduction of 16.99 ML/d on the River Dart.

There will be sufficient water resource available to supply the developments detailed in the Torbay consultation.

This is a link to the Water Resources Management Plan published by South SWW: -
Water resources management plan | South West Water.


Wastewater Network

Within the Torbay local plan 57 sites can have their foul flows accommodated within the existing wastewater network and infrastructure. The 57 sites identified are considered to be likely to have a low impact and are not expected to require significant upgrades to the wastewater network from the Undertaker’s high-level assessment. As the allocations progress, if it is determined that any network upgrades are required, this would be funded through the Infrastructure Charge that SWWL imposes on developers.

Four of the sites (H2P.4, H2P.3, H3P.3 and H2T.1) within the Torbay local plan are considered to pose a medium impact on the existing wastewater network; as based upon the size or location of the development, these proposed sites are likely to require some upgrades to the wastewater network to accommodate their foul flows. Further assessment would be required relating to specific proposed details to assess the particular scale and specifics of required upgrades.

 
Wastewater Treatment

Brokenbury Quarry Sewage Treatment Works

The foul flows of the sites included within the Torbay Local Plan would be treated at the Brokenbury Quarry sewage treatment works. It is planned to invest in the sludge treatment process at Brokenbury Quarry STW within the next ten years. However, the existing works do have sufficient treatment capacity to deal with the foul flows that would be generated by all the sites identified within the Torbay local plan.