The background evidence includes the Essex Thames Gateway Water Cycle Study Scoping Report carried out by Scott Wilson and completed in March 2009 however the findings of this report have failed to be captured in the policies of the Core Strategy (with the exception of the water efficiency requirements related to the Code for Sustainable Homes in Policy ENV9).

The Scoping Report identifies that in terms of water resources, Essex and Suffolk Water are currently operating at a demand-supply deficit during dry years and that, although the approval of the Abberton reservoir scheme will largely alleviate these problems in the future, the deficit will remain until this scheme comes online in 2014. The Scoping Report therefore recommends that, as well as seeking high levels of water efficiency in new and existing developments, new development is phased up to 2014.

In addition to the water resources issue, the Scoping Study also that there are some potential capacity issues with both the Rochford Wastewater treatment works (WwTW) and the sewerage network associated with it which would need resolving around 2015. There might also be some issues with the quality of discharge from the Rayleigh East WwTW which will require further investigation but could be exacerbated by unphased growth.

In terms of water quality, the three WwTWs serving Rochford District - Rochford, Rayleigh East and Rayleigh West - discharge to tributaries of the Rivers Roach and Crouch which are Shellfish Waters and flow into areas designated under national and international environmental legislation (SSSI, SPA and Ramsar designations) and the water quality of these watercourses is generally poor. Page 48 of the Scoping Study states that further development draining to these three WwTWs has the potential to exacerbate the problem. Again further investigation is required into this issue.

In not addressing the findings of this report we deem the Core Strategy to be unsound in that it is not effective. This is because we do not believe that the Policies set out in the Core Strategy have clearly identified the infrastructure implications of the strategy and the delivery mechanisms and timescales for implementation have not been addressed. There is also an element of inflexibility in failing to recognise the findings of this report and the potential impact on growth delivery.

In order to make the Core Strategy sound, it must incorporate the findings of the Water Cycle Study Scoping Report and recognise the potential constraints to development delivery.

Referring to the report in Policy H3 would be an option. At this stage in the process we would consider it sufficient to include a statement about the intention to phase development in line with the findings of the Scoping Report and subsequent Outline and Detailed Stage Water Cycle Studies. The Site Allocations DPD would require more detailed information to inform the phasing so as to avoid bringing forward sites prematurely.

Please note that should the Inspector deem it necessary for us to attend the Examination in Public, we would be happy to do so but our preferred method at this time would be written representations.