We are supportive of new sustainable development and the plan in general. However, as you must be aware there is a huge problem with the sewage infrastructure nationally, but particularly in Whitstable, with Tankerton beach being one of the worst in the Country for pollution. 
Therefore, we would suggest that the water companies should have to work with developers and the Council to ensure that no new development is going to make the problem worse.
We have seen this achieved in other Council locations with a requirement for the following type of planning condition to be attached to all major developments, and suggest Canterbury Council do the same:
 
Please see attached document - 


Unless otherwise approved in writing by the Local Planning Authority, there shall be no
piped discharge of surface water from any completed phase of the development prior
to the completion of the approved sustainable surface water drainage works for that phase and no
buildings shall be occupied or brought into use within that phase prior to completion of
the approved foul drainage works
 
To ensure that no foul or surface water discharges take place until proper provision has
been made for their disposal, in accordance with the NPPF.
 
No properties shall be occupied until confirmation has been provided that either:-
all surface water and wastewater network upgrades required to accommodate the
additional flows from the development have been completed; or - a housing and
infrastructure phasing plan has been agreed with Southern Water to allow additional
properties to be occupied. Where a housing and infrastructure phasing plan is agreed no
occupation shall take place other than in accordance with the agreed housing and
infrastructure phasing plan.
 
Reason: The development may lead to flooding and network reinforcement works are anticipated
to be necessary to ensure that sufficient capacity is made available to accommodate additional
flows anticipated from the new development. Any necessary reinforcement works will be
necessary in order to avoid sewer flooding and/or potential pollution incidents.
 
No properties shall be occupied until confirmation has been provided that either:-
all water network upgrades required to accommodate the additional flows from the
development have been completed; or - a housing and infrastructure phasing plan has
been agreed with Southern Water to allow additional properties to be occupied. Where a
housing and infrastructure phasing plan is agreed no occupation shall take place other
than in accordance with the agreed housing and infrastructure phasing plan.
 
Reason: The development may lead to no / low water pressure and network reinforcement works
are anticipated to be necessary to ensure that sufficient capacity is made available to
accommodate additional demand anticipated from the new development.
 
Details of a sustainable drainage system shall be submitted to and
approved by the Local Planning Authority prior to the construction of the
new building, and the development shall be carried out in accordance with
the approved details.
 
Reason: To ensure that surface water run-off is attenuated in a satisfactory
manner to minimise the risk of the proposed development contributing to
local flooding, and to ensure that general water
 
Before any drainage works are commenced on site, detailed plans, giving
notice of intention to build/permission to drain/construct/reconstruct or
alter pipes and drains must be submitted for approval under the Building
Regulations 1991 to Building Control Service, [contact details]. 
 
Please note that it will be necessary to consult the Southern Water [ contact details] regarding the below
.
 
1) All information appertaining to the existing public sewerage system.
2) Requests for sewer connections. All works will be carried out by the
Council at the applicant expense. All new developments will be required to have new sewer connections.
3) Building over sewers.
4) System of drainage to be provided on site.
5) Adoption of sewers.
 
Advisory Note:
It should be noted that most sewers throughout the County flow full or
surcharge during periods of heavy storm and conditions may be imposed
restricting discharge to the system. The prime condition is that any large
development shall not cause an increase in the rate of flow to the public
sewerage system. This requirement is normally met in the case of new
developments by separation on site and storage of surface water flows in
tanks or oversized pipes on sites. Where sites adjoin a suitable watercourse
or storm relief sewer into which surface water can be discharged by gravity
then the policy is for sites to be separated and have their surface water
discharged to the watercourse or storm relief sewer. In the case of
developments/ rehabilitation/ conversions etc., involving the use of
basements these are likely to be particularly vulnerable to the effects of
surcharge and applicants must therefore demonstrate that adequate
drainage arrangements exist at all times