Support

Representation ID: 4620

Received: 10/03/2026

Respondent: Mr Stephen Davies

I have read the 'Hough on the Hill Neighbourhood Plan Review - Submission Version' and I am happy to support this document.

Comment

Representation ID: 4641

Received: 12/03/2026

Respondent: Ms Marilyn Taylor

I do not support the addition of an explanatory note at Annexe 1 regarding reference to the Design Guidance and Design Codes (August 2022) prepared by AECOM because this document is not available anywhere so how could reference be made to it?
I also query whether any updated Design Guidance (Annexe 1) can simply be adopted without having to again submit the Plan for assessment under neighbourhood planning regulations?

I also submit that the Plan contains inadequate information regarding public consultation and involvement in the preparation of the proposed modifications with all decisions made behind closed doors, excluding resident involvement.

Comment

Representation ID: 4673

Received: 30/01/2026

Respondent: Forestry Commission

Thank you for inviting the Forestry Commission to respond to the consultation on the Neighbourhood Plan, Unfortunately, we do not have the resources to respond to individual plans but we have some key points to make relevant to all neighbourhood plans.

Forestry Commission and Neighbourhood Planning

Existing trees in your community
The Forestry Commission would like to encourage communities to review the trees and woodlands in their neighbourhood and consider whether they are sufficiently diverse in age and species to prove resilient in the face of tree pests and diseases or climate change. For example, if you have a high proportion of Ash, you are likely to see the majority suffering from Ash Dieback. Some communities are proactively planting different species straight away, to mitigate the effect of losing the Ash; you can find out more here. Alternatively, if you have a high proportion of Beech, you may find they suffer particularly from drought or flood stress as the climate becomes more extreme. There are resources available to help you get ideas for other species you can plant to diversify your tree stock and make it more resilient.

Ancient Woodland
If you have ancient woodland within or adjacent to your boundary it is important that it is considered within your plan. Ancient woodlands are irreplaceable, they have great value because they have a long history of woodland cover, with many features remaining undisturbed. This applies equally to Ancient Semi Natural Woodland (ASNW) and Plantations on Ancient Woodland Sites (PAWS). It is Government policy to refuse development that will result in the loss or deterioration of irreplaceable habitats including ancient woodland, unless “there are wholly exceptional reasons and a suitable compensation strategy exists” (National Planning Policy Framework paragraph 180).
The Forestry Commission has prepared joint Standing Advice for the treatment of Ancient Woodland
If you have ancient woodland within or adjacent to your boundary it is important that it is considered within your plan. Ancient woodlands are irreplaceable, they have great value because they have a long history of woodland cover, with many features remaining undisturbed. This applies equally to Ancient Semi Natural Woodland (ASNW) and Plantations on Ancient Woodland Sites (PAWS). It is Government policy to refuse development that will result in the loss or deterioration of irreplaceable habitats including ancient woodland, unless “there are wholly exceptional reasons and a suitable compensation strategy exists” (National Planning Policy Framework paragraph 180).
The Forestry Commission has prepared joint Standing Advice with Natural England on ancient woodland and veteran trees. This advice is a material consideration for planning decisions across England and can also be a useful starting point for policy considerations.
The Standing Advice explains the definition of ancient woodland, its importance, ways to identify it and the policies that relevant to it. It provides advice on how to protect ancient woodland when dealing with planning applications that may affect ancient woodland. It also considers ancient wood-pasture and veteran trees. It will provides links to Natural England’s Ancient Woodland Inventory and assessment guides as well as other tools to assist you in assessing potential impacts.

Deforestation
The overarching policy for the sustainable management of forests, woodland and trees in England is a presumption against deforestation.

Woodland Creation
The UK is committed in law to net zero emissions by 2050. Tree planting is recognised as contributing to efforts to tackle the biodiversity and climate emergencies we are currently facing. Neighbourhood plans are a useful mechanism for promoting tree planting close to people so that the cultural and health benefits of trees can be enjoyed alongside their broader environmental benefits. Any planting considered by the plan should require healthy resilient tree stock to minimise the risk of pests and diseases and maximise its climate change resilience, a robust management plan should also be put in place.
with Natural England on ancient woodland and veteran trees. This advice is a material consideration for planning decisions across England and can also be a useful starting point for policy considerations.
The Standing Advice explains the definition of ancient woodland, its importance, ways to identify it and the policies that relevant to it. It provides advice on how to protect ancient woodland when dealing with planning applications that may affect ancient woodland. It also considers ancient wood-pasture and veteran trees. It will provides links to Natural England’s Ancient Woodland Inventory and assessment guides as well as other tools to assist you in assessing potential impacts.

Deforestation
The overarching policy for the sustainable management of forests, woodland and trees in England is a presumption against deforestation.

Woodland Creation
The UK is committed in law to net zero emissions by 2050. Tree planting is recognised as contributing to efforts to tackle the biodiversity and climate emergencies we are currently facing. Neighbourhood plans are a useful mechanism for promoting tree planting close to people so that the cultural and health benefits of trees can be enjoyed alongside their broader environmental benefits. Any planting considered by the plan should require healthy resilient tree stock to minimise the risk of pests and diseases and maximise its climate change resilience, a robust management plan should also be put in place.

Comment

Representation ID: 4674

Received: 02/02/2026

Respondent: Historic England

Thank you for consulting us on the Regulation 16 Consultation of the Hough on the Hill Neighbourhood Plan.

We have no further comments to make in addition to those we made at Regulation 14 stage - a copy of which I have attached for your information.

Comment

Representation ID: 4685

Received: 03/03/2026

Respondent: Witham Third Internal Drainage Board

Thank you for the opportunity to comment on the Neighbourhood Plan.

Some of the lower parts of the area of interest fall within the Upper Witham Internal Drainage Board’s District and include a number of Board maintained watercourses, plans and/or shape files are available on request. More information about the Board can be found on the website ‘https://witham3idb.gov.uk/upper-witham-internal-drainage-board/ ‘. Most of the existing property has been built on higher ground outside the District although there are several properties on Brandon Road that are within the Board’s District in an area that can be considered at risk of flooding.

It should also be noted that there have been some flooding/ground water issues in the village of Brandon.

The area of interest is situated in an area where the watercourses are unable to accept any increase in the rates of discharge; therefore, any development must prove the existence of a surface water drainage route and provide adequate proposals to make certain that flood risk is not increased elsewhere as a result of any proposed development.

It is suggested that the Neighbourhood Plan should support the idea of sustainable drainage and that any proposed development should be in accordance with National and Regional Flood Risk assessments and Management plans.

No new development should be allowed to be built within flood plain. The ‘Flood Maps’ on the Environment Agency website provides information on areas at risk, information can be found by searching ‘EA flood maps’. The Plan refers to Flood Zones, but no maps are included. Also risk from surface water flooding should also be considered, information can also be found on the Environment Agency website. It can be found by search using ‘EA surface water flood map’

Under the terms of the Land Drainage Act. 1991 and the Board's Byelaws, the prior written consent of the Board is required for any proposed works or structures in, under, over or within 9 metres of the top of the bank of any Board maintained watercourse within the District. For all other riparian watercourses consent is required for any works within a watercourse. This is independent of the Planning Process.

Also, under the provisions of the Flood and Water Management Act 2010, and the Land Drainage Act. 1991, the prior written consent of the Lead Local Flood Authority (Lincolnshire County Council) is required for any proposed works or structures in any watercourse outside those designated main rivers and Internal Drainage Districts. In this area the Board acts as Agents for the Lead Local Flood Authority and as such any works, permanent or temporary, in any ditch, dyke or other such watercourse will require consent from the Board. This is independent of the Planning Process.

In 39
It states ‘Watercourses within the parish boundary are therefore likely to be managed by either
Lincolnshire County Council or the Upper Witham Internal Drainage Board.’ This is misleading and implies they are responsible for maintenance. This is NOT the case as most watercourses are riparian and maintenance is the responsibility of the landowner (or adjacent landowner). Lincolnshire CC as the LLFA, Lead Local Flood Authority would be useful to contact for further information and advice.

Comment

Representation ID: 4687

Received: 07/03/2026

Respondent: Steven Bacon

I am against the inclusion of ‘green spaces’ in the neighbourhood plan and as am writing to you in order that you take account of my opinion in your deliberations

Support

Representation ID: 4689

Received: 07/03/2026

Respondent: Chris Seage

I have reviewed the new plan and am in agreement with the contents. The omission of the green spaces is a good policy as it is unnecessary in a conservation area and caused great distress to those involved

Comment

Representation ID: 4690

Received: 08/03/2026

Respondent: Helen Tyrrell

I am a resident in Hough on the hill and do not support the inclusion of green spaces in the neighbourhood plan

Support

Representation ID: 4692

Received: 08/03/2026

Respondent: Matt Martin

I have reviewed the new plan and am in agreement with the contents. The omission of the green spaces is a good policy as it is unnecessary in a conservation area and caused great distress to those involved. In conclusion I cannot understand how a protection of green space land by individuals over the property of others could be put in place or how it was ever legal!

Comment

Representation ID: 4693

Received: 08/03/2026

Respondent: Manuela Watson

I have looked at the most recent plan and in general I agree with the contents.
But I believe as the village is already in a conservation area, the suggestion that every thing should be included in the "green spaces" is not only unnecessary, but fundamentally wrong to all those affected. It will create huge upset and most certainly will result in some further mental ill health issues.

Comment

Representation ID: 4697

Received: 09/03/2026

Respondent: National Gas

Representations on behalf of National Gas Transmission

National Gas Transmission has appointed Avison Young to review and respond to Neighbourhood Plan consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.

About National Gas Transmission National Gas Transmission owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use.

Proposed sites crossed or in close proximity to National Gas Transmission assets:
An assessment has been carried out with respect to National Gas Transmission’s assets which include high-pressure gas pipelines and other infrastructure.

National Gas Transmission has identified that no assets are currently affected by proposed allocations within the Neighbourhood Plan area.

National Gas Transmission provides information in relation to its assets at the website below.

• https://www.nationalgas.com/land-and-assets/network-route-maps
Please also see attached information outlining guidance on development close to National Gas Transmission infrastructure.

Distribution Networks
Information regarding the gas distribution network is available by contacting:
plantprotection@cadentgas.com

Further Advice
Please remember to consult National Gas Transmission on any Neighbourhood Plan Documents or site-specific proposals that could affect our assets.

Comment

Representation ID: 4700

Received: 09/03/2026

Respondent: Judith Sharman

I would like to comment on the proposed neighbourhood plan for Hough on the Hill. Generally I feel it is well crafted and takes into account the parish consists of 3 villages each with very different characteristics. I therefore approve this approach to having specific plans for different areas I am concerned however by the inclusion of some of the houses of special interest. I wonder what criteria they are measured against? One especially has a metal up and over garage door, composite windows and modern white render. Perhaps this element of the plan should be reviewed I also approve the omission of the local green spaces. The NPPF states this is not necessary in a conservation area and should not be used as a back door way of providing green belt. It has caused a great deal of community conflict and is better left alone.

Comment

Representation ID: 4702

Received: 10/03/2026

Respondent: National Highways

Thank you for providing National Highways with the opportunity to consult on the draft Neighbourhood Plan for The Hough on the Hill.

National Highways (formerly Highways England) has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth.

In responding to development plan consultations, we have regard to DfT Circular 01/2022: The Strategic Road Network and the Delivery of Sustainable Development (‘the Circular’). This sets out how interactions with the Strategic Road Network should be considered in the making of plans and development management considerations. In addition to the Circular, the response set out below is also in accordance with the
National Planning Policy Framework (NPPF) and other relevant policies.

In relation to the The Hough on the Hill Neighbourhood Development Plan, our principal interest is in safeguarding the operation of the SRN, the nearest route which is the A1 which is approximately 4km away. The scope and scale of proposed development identified in the The Hough on the Hill Neighbourhood Development Plan, is modest and shall not have any significant impact on the operation of the SRN.

Considering the limited level of growth proposed across the Neighbourhood Development Plan area, we do not expect that there will be any significant impacts on the operation of the SRN.

Comment

Representation ID: 4703

Received: 11/03/2026

Respondent: Mr Robert Moore

I only have two suggestions for the Hough on the Hill Neighbourhood Plan Review (https://www.southkesteven.gov.uk/hough-hill-review)

These are:

•A typo on p22, para 72: "Wayside Farm" is included in the final bullet point but doesn't belong with that bullet point; it should have its own bullet point (it did in the original NP too).
•P43, para119, policy HoH6 has had the following removed "...a positive unlisted building/locally listed building... or any other structure of local significance". I think these should not be deleted and be placed back in this update.

Comment

Representation ID: 4704

Received: 11/03/2026

Respondent: Canal and River Trust

We are the charity who look after and bring to life 2000 miles of canals & rivers. Our waterways contribute to the health and wellbeing of local communities and economies, creating attractive and connected places to live, work, volunteer and spend leisure time. These historic, natural and cultural assets form part of the strategic and local green-blue infrastructure network, linking urban and rural communities as well as habitats. By caring for our
waterways and promoting their use we believe we can improve the wellbeing of our nation. The Canal & River Trust (the Trust) is a statutory consultee in the Development Management process, and as such we welcome the opportunity to input into planning policy related matters to ensure that our waterways are protected, safeguarded and enhanced within an appropriate policy framework.

The Trust have no waterways, assets or land interests within the area covered by the document and as such we have no comment to make.

Comment

Representation ID: 4705

Received: 12/03/2026

Respondent: Natural England

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England is a statutory consultee in neighbourhood planning and must be consulted on draft neighbourhood development plans by the Parish/Town Councils or Neighbourhood Forums where they consider our interests would be affected by the proposals made.

Natural England does not have any specific comments on this draft neighbourhood plan.

However, we refer you to the attached annex which covers the issues and opportunities that should be considered when preparing a Neighbourhood Plan and to the following information.

Natural England does not hold information on the location of significant populations of protected species, so is unable to advise whether this plan is likely to affect protected species to such an extent as to require a Strategic Environmental Assessment. Further information on protected species and development is included in Natural England's Standing Advice on protected species .

Furthermore, Natural England does not routinely maintain locally specific data on all environmental assets. The plan may have environmental impacts on priority species and/or habitats, local wildlife sites, soils and best and most versatile agricultural land, or on local landscape character that may be sufficient to warrant a Strategic Environmental Assessment. Information on ancient woodland, ancient and veteran trees is set out
in Natural England/Forestry Commission standing advice.

We therefore recommend that advice is sought from your ecological, landscape and soils advisers, local record centre, recording society or wildlife body on the local soils, best and most versatile agricultural land, landscape, geodiversity and biodiversity receptors that may be affected by the plan before determining whether a Strategic Environmental Assessment is necessary.

Natural England reserves the right to provide further advice on the environmental assessment of the plan. This includes any third party appeal against any screening decision you may make. If an Strategic Environmental Assessment is required, Natural England must be consulted at the scoping and environmental report stages.

Comment

Representation ID: 4708

Received: 13/03/2026

Respondent: David Hindmarch

I support the above plan, concluding that green spaces should be excluded. Local people generally do not feel green space creation is necessary given that we live in such. rural area.

Comment

Representation ID: 4716

Received: 20/02/2026

Respondent: West Lindsey District Council

Thank you for your letter in relation to the Hough on the Hill Neighbourhood Plan Review.

I can confirm that West Lindsey District Council have no comments to make.

Comment

Representation ID: 4717

Received: 13/03/2026

Respondent: Lincolnshire County Council

The Hough on the Hill SEA /HRA Screening Opinion Modified Version (2025) states that the proposed modifications are not likely to have significant environmental effects. Therefore, a Strategic Environmental Assessment (SEA) is not required (and nor is an HRA). It also confirms that references to the NPPF (2024) and the SKLP (2020) have been updated.

The Hough on the Hill Modification Proposal Statement states in its conclusion that proposed modifications are compliant as follows:-

•3.2 The proposed modifications are consistent with the spirit, vision and objectives of the Made Plan and are necessary to ensure that the Plan remains in conformity with the revised NPPF (December 2024) and The South Kesteven Local Plan (adopted January 2020), both of which have come in to effect since the date the Hough on the Hill Neighbourhood Plan was made in July 2015.

•3.3 Taken as a whole, the proposed modifications are considered to be “material modifications which do not change the nature of the plan”. It is, therefore, considered that, subject to consideration by an independent examiner, the modifications may be made without a referendum.

Some modifications that we have noted are described as follows:-

•5. Neighbourhood Plan Policies Sustainable Development (and elsewhere): References to NPPF updated. ……. To ensure consistency with latest version of the NPPF (December 2024).
•Policy HoH6: Terminology changed from “positive unlisted building/locally listed building or any other structure of local significance”, to “non-designated heritage asset”
•Policy HoH14: Title “Renewable and Low Carbon Energy for Businesses” added after policy number.
•Policy HoH15: Title “Maintaining and Improving Access to the Countryside” added after policy number

Consultation Statement (March 2025, updated Nov 2025) - Responses/actions that we have noted

No responses on the proposed modifications were noted from LCC. Although the amendments were not deemed to be material, and formal consultation was not statutorily required, some consultation was nevertheless carried out. (App1, page 40, Consultation Statement).

•SKDC officer advised on a number of points to improve compliance with the adopted SKDC Local Plan as described in the Consultation Statement that has been submitted with this review of the NP.
•The Parish Council will explore, in partnership with the SKDC Conservation Officer, an appropriately evidenced process for compiling a Local List of buildings of architectural or historic interest, including within such consideration those ‘positive unlisted buildings’ identified within the Hough on the Hill Conservation Area (6 Non Planning Issues Page 102).
•The “Neighbourhood Planning Questionnaire Feb 2022” asked which areas should be designated as Green Spaces. Following a number of suggestions, there is a statement “A great deal of further work is required to identify eligible and appropriate locations for potential Green Space designation and consultants from AECOM will be working with us on this during the coming months. There will, of course, be further consultation, especially with landowners.”
•The Environment Agency (EA) responded on a number of issues including “support the inclusion of the ‘Green Spaces: Protecting Greenspace and Support Nature Conservation and Biodiversity’ section and NDP objective.”
•EA also suggested “that the water environment/blue infrastructure is also included as it is important to consider blue and green infrastructure together as water is vital to the health of greenspaces and biodiversity.”
•Comments were made about the Design Code. The Action noted was to develop the Design Code and guidance further, including further consultation. I don’t think this has been developed further yet.


Typos
Page 8 History and Heritage 11. Line 1 “dating, dating from the Bronze Age” (the word “dating” should be stated once only)
Page 11 Housing. Last line of paragraph. There is a full stop where there shouldn’t be one “…. like to be housed. In Hough on the Hill…..”
Page 12: Transport and Movement – The last line and sentence “In particular, the permissive footpath” appears to be unfinished.
Page 14: Flood Risk, Water Quality and Geology 39 (line 7) LLFA should be set out in full (Lead Local Flood Authority) as this is the first time this acronym has been used, and there is no glossary.
Page 19: Para 58 Objectives . Bullet 4 “Encouraging” should be in the subsequent bullet point.
Page 19: Para 58 Objectives. Bullet 6 “Seeking” should be in the subsequent bullet point.
Page 19: Para 58 Objectives. Is the last bullet point really a bullet point?

Page 17 Design Guidance – Consultation in 2014 supported a “positive approach rather than just listing what’s not permitted”.

Page 36 NP: 107 “Policies to be read in conjunction with the Design Guidance, (Annex 1), the H on the H Landscape Character Assessment (Oct 2013) provided in App 1, and the ‘Key Views I the Parish’ shown in Figure 6 (page 31). (Character Assessment can be found on the H on the H PC website here: 2448-RE-Hough 01d vr).


Non-designated heritage assets

•Page 17 (Table) Valued unlisted structures appear to have been identified either within the NP (page 22), in the SKDC Conservation Area 2014 Draft Review and in the Appraisal and Management Plan 2014
•Page 40 115 “Heritage assets with the H on the H NP include (et al)
•Locally listed buildings, ‘Positive Unlisted Buildings’ or other non-designated heritage assets ......... within the .....Appraisal and Management Plan, 2014 ……..”

•There is a list of “Positive Unlisted Buildings” for the village of Hough on the Hill listed on page 22 of the NP. They are an extract from the Conservation Area Appraisal and Management Plan 2014. This document is not listed as an Appendix to the NP nor any links to it.

Local Green Spaces
•Page 19 Para 59 Bullet 3 reports that “ Loveden Hill will be highlighted and protected through its designation as a Local Green Space.”

Views

•Views are mentioned in para 61 on page 20 for H on the H.
•Important Views Index for Hough on the Hill is listed on page 25. The map of H on the H on page 24 includes directional arrows for these views.
•Chapter 4 Opportunities and Constraints starting on page 20 sets out a clear description of the character and features of interest of the village of Hough on the Hill. It lists
•“Positive Unlisted Buildings”
•Listed Buildings
•2 Important Open Spaces (Augustinian Priory Site and the Parish Playing Field)
•A map of Hough on the Hill Conservation Area showing:-

oViews – Important and Important Panoramic
oImportant Open Space (I don’t think this accords with the two sites listed)
oListed Buildings
oPositive Unlisted buildings
oSAMs
oArea of Visual Dominance (the church – though clearly important it is not listed as an Important Open Space)
oConservation Area Boundary
oRidge and Furrow
•Important Views Index

Although the subsequent descriptions of Gelston and Brandon set out interesting character and features of the villages, they do not include the useful Hough on the Hill map showing location of the views or the listed or undesignated buildings et al or a clear index for these features.

There is, however, a useful map on page 34 setting out the key views across the whole Parish.

Chapter 5 NEIGHBOURHOOD PLAN POLICIES

•The various policies note LGS and important spaces and green spaces but we don’t think the document clearly indexes either Local Green Spaces or Important Open Spaces clearly. The emphasis is clearly on H on the H and not on the other two villages.

•Although there is mention of renewable energy throughout the document, the emphasis has been placed on small-scale domestic (and business HoH14) renewables (HOH12) and community-led (HOH13) energy initiatives.

•Policies for HoH5 (Listed Buildings) and HoH6 (NDHAs) contain identical wording which might suggest the same weight is given to NDHAs as to listed buildings. A small amendment to the HoH6 policy text would resolve this.

•Policy HoH12 (Energy Efficiency and Renewable Energy) focuses mainly on new development and could acknowledge that energy efficiency improvements to historic/listed buildings may be supported where sensitively designed and consistent with their significance.

NSIPS
•Given the rural historic landscape context of the parish, the plan could optionally acknowledge that larger infrastructure proposals should consider impacts on the wider historic landscape setting and key views.

"Positive Unlisted Buildings"
•It would be helpful to clarify whether these buildings are intended to function as NHDAs for decision-making purposes, as its not a term I've come across before (although that may just be me). The plan does say it is working with LPA to progress proposals for a local list, which would likely resolve this.

Comment

Representation ID: 4718

Received: 13/03/2026

Respondent: Environment Agency

A key principle of the planning system is to promote sustainable development. Sustainable development meets our needs for housing, employment and recreation while protecting the environment. It ensures that the right development, is built in the right place at the right time.

To assist in the preparation of any document towards achieving sustainable development we have identified the key environmental issues within our remit that are relevant to this area and have provided guidance on any actions you need to undertake.

We aim to reduce flood risk, while protecting and enhancing the water environment. Our comments on this matter are therefore made solely from these points of view.

Environmental Constraints

Flood risk
We encourage all proposed development to be outside of Flood Zone 2 and Flood Zone
3. However, if there is no other choice other than to build in Flood Zone 2 or Flood Zone
3, then you will need to undertake and pass both the Sequential Test and Exception
Test and carry out appropriate flood risk assessments.

If Essential Infrastructure is necessary within Flood Zone 3 then the application must be referred to the Environment Agency together with a supporting Flood Risk Assessment, which demonstrates that the proposal will remain operational during a 0.1% event (2115 scenario) and that appropriate mitigation measures/flood resilient construction techniques have been incorporated into the development.

Water quality and foul drainage
The Neighbourhood Plan states in section 40 (page 14) “Hough on the Hill drains into the River Brant catchment, with the village being served by a small Anglian Water Sewage Treatment Works. The Upper Brant is failing good status due to elevated levels of phosphate. The lower River Brant is also at poor ecological status.”

We can confirm that that the Hough on the Hill sewage treatment works does discharge to the Upper Brant (Water Framework Directive (WFD) waterbody ID GB105030056110) and that the failure is due to phosphate. One of the confirmed reasons for this is the continuous discharge from the water company sewage treatment works.

Further details can be found here: Brant - Upper | Catchment Data Explorer | Catchment Data Explorer

The Neighbourhood Plan does not include a drainage strategy. We would expect, and recommend, one of these to be included to outline how new developments will ensure that the surface water and foul flows from their sites will not cause deterioration to any WFD waterbodies.

We would also advise you to consult and liaise with Anglian Water regarding the capacity of the Hough on the Hill sewage treatment works to take on additional flows from new developments without causing deterioration in the receiving watercourse.

It should also be noted that there are two other WFD catchments in the Hough on the Hill Parish boundary: Honington Beck (GB105030056750) and Sand Beck (GB105030056160). How the Plan can protect these waterbodies should also be considered, particularly if development is proposed within them.

Paragraph 42 (page 14) states that “The majority of properties (and all properties within Brandon and Gelston) are not on mains drainage”. One of the Environment Agency's principle concerns regarding foul water management is to prevent the proliferation of non-mains treatment solutions wherever possible. We advise that the Plan should encourage developments to connect to the mains wherever practicable. We would suggest some wording is included in the Plan to advise of the following:

The Building Regulations 2010 and Government Guidance contained within the PPG for Water Supply, Wastewater and Water Quality (paragraph 020 ID: 34-020-20140306) sets out a hierarchy of drainage options that must be considered and discounted in the following order:
1. Connection to the public sewer
2. Connection to a private sewer that drains to a public sewer
3. Package sewage treatment plant or septic tank
4. Cesspool

Foul drainage should be connected to the main sewer whenever it is feasible to do so. Where this is not possible, under the Environmental Permitting (England and Wales) Regulations 2016 any discharge of sewage or trade effluent made to either surface water or groundwater will need to either comply with General Binding Rules for Small Sewage Discharges or comply with a permit issued by the Environment Agency, additional to any planning permission that may be required. This applies to any discharge to ground, inland freshwaters, coastal waters or relevant territorial waters. Further information about the permitting process can be found at Septic tanks and sewage treatment plants: what you need to do.

Further advice is available at: Septic tanks and treatment plants: permits and general binding rules

Any future developments should also look at including measures for improving and enhancing the water environment where possible.

Biodiversity
We support the inclusion of the ‘Green Spaces: Protecting Greenspace and Support Nature Conservation and Biodiversity’ section and Neighbourhood Plan objective.

We note that Green Infrastructure is also mentioned in the plan. We would suggest that the water environment / blue infrastructure is also included as it is important to consider blue and green infrastructure together as water is vital to the health of greenspaces and biodiversity.

Groundwater and contaminated land
National Planning Policy Framework (NPPF) paragraph 187 states that the planning system should contribute to and enhance the natural and local environment by preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of water pollution. Government policy also states that planning policies and decisions should also ensure that adequate site investigation information, prepared by a competent person, is presented (NPPF, paragraph 196).

With this in mind we recommend adding the following to section 41 of the Plan on the topic of ‘Flood Risk, Water Quality and Geology’:

The western part of the parish is also underlain by superficial geology comprising the Fulbeck Sand and Gravel Member, which is also classified as a secondary A aquifer.

These aquifers can support local abstractions and baseflow to streams and rivers. The use (or potential use) of groundwater in the area makes parts of the area vulnerable to pollution from certain types of development. Best practice to ensure groundwater is protected from pollution and as a resource is contained within guidance document ‘The Environment Agency’s approach to groundwater protection’ available Groundwater protection position statements - GOV.UK.

This publication sets out our position for a wide range of activities and developments, including:
• Waste management
• Discharge of liquid effluents
• Land contamination
• Ground source heat pumps
• Cemetery developments
• Drainage

Comment

Representation ID: 4807

Received: 12/03/2026

Respondent: South Kesteven District Council

Please see attached for SKDC Planning Policy's response to Hough on the Hill Draft Neighbourhood Plan Review