Author: samuel draper
Company: Isle of Wight Council

The Legislation 

What will the sewers which transfer ownership on 1^st October be referred to as? 
These sewers will be referred to as “Section 105a” sewers and laterals to differentiate them from the current public sewers. 

Will there be any changes to the ownership of highway drains? 
No, these will remain the responsibility of the local authorities. 

Does the transfer include SUDs? 
Surface water systems which discharge directly to the environment will not transfer ownership to Southern Water. Similarly those structures which do not meet the legal definition of private sewer will not transfer. 

How does the transfer affect multi-occupancy sites e.g. blocks of flats, caravan sites, industrial units, retail sites? 
This depends on how curtilage is defined for such sites, which is generally site specific. There is no regulatory definition for curtilage and a single curtilage may be defined even if the industrial or commercial units are under separate ownership. In 
other words, ownership status is not always definitive. 

Are there any plans for private wastewater treatment works to transfer ownership in future? 
No, there are no plans for such a transfer at present. 

Does the transfer include above ground property drainage? 
No, this is not included in the transfer. 

Will Southern Water have maps for these newly transferred sewers? 
Southern Water does not currently possess maps for the Section 105a assets. However, we will be mapping these as part of our business as usual process when attending incidents to build up the mapping. We are also looking to capture any data 
from external organisations which is compatible with our GIS system. 

How will any new mapping be transferred to the Local Authorities? 
Southern Water provide quarterly updates from our GIS system so over time you will start to see the Section 105a sewers on the mapping. 

What impact will this transfer have on customer bills? 
The additional work we are taking on means that bills will go up in future, but not immediately. The cost to customers has been estimated by Defra to be between £3 and £14 a year. The estimate may be reviewed in light of actual demand following transfer. 

Different water companies are quoting different figures for the bill increase, will this be regulated? 
Price increases are currently estimated as we do not know the full extent or impact of these new assets. Prices will also vary from region to region depending on the type, condition and performance of the assets which transfer ownership. Any increase in 
customer’s bills will be subject to the approval process set down by our Regulator Ofwat. 

What will happen if Local Authorities have existing repair notices served on private sewer owners which will become Southern Water’s responsibility on 1st October? Will Southern Water inspect repairs on public drains in such circumstances? 
In some cases we may take these issues over and carry out repairs. However, if a customer’s insurance company has already started work they may continue with the appropriate approvals even though they will be working on a Southern Water owned 
asset after 1st October. Where a repair has already been carried out or is completed, further inspections are unlikely. If no repairs have been commenced, then provided 
Southern Water are aware of the relevant repair notices, inspection of the relevant pipework may well follow in order to assess the works which are needed. 

Has Southern Water received many appeals? 
Appeals are being handled by Ofwat but we are only aware of a small number in our region. Customers will need to be able to satisfy the “detriment” criteria as a result of the transfer in order to successfully appeal. 

Will Southern Water carry out repair work during the 
appeals process? 
Southern Water will not take ownership of any assets upstream of an asset under appeal, or the asset itself. Ofwat will work quickly to resolve any appeals so this is unlikely to present significant problems but if such cases arise Southern Water will 
take a view on whether or not to carry out repairs, should the asset owner fail to do so. 

Southern Water’s Response to the Legislation 

Has Southern Water’s call centre number changed? 
No, our contact number remains 0845 278 0845. Customers will be asked to select one of three options: water supply and leakage issues; sewers and drainage issues; or billing enquiry. Lines are open 24hours a day. Between 8am and 6pm Mon-Fri and 8am to 1pm Saturday all calls relating to sewers and drains will be directed to the new 
customer contact centre in Falmer. Outside of these hours calls will be directed to the Regional Control Centre in Durrington. We are currently reviewing our opening hours with a view to extending these. 

What is Southern Water’s response time for surface water flooding? 
Our target response times for surface water flooding are 1 hour and 6 hours for priority 1 incidents (internal and external flooding and pollution) on Section 105a sewers and the existing public sewer network respectively, and 6 hours and 24 hours for priority 2 incidents e.g. blockages and missing manhole covers. 

Do the response times apply 24 hours a day? 
Yes, although we will be honest with customers and in times of high demand. If the response time is likely to be more than the target we will inform the customer of the anticipated delay. 

If the location of a blockage is not clear will Southern Water work to get it cleared or contest who is responsible for the sewer? 
If there is any doubt over the ownership of the sewer at the point of customer contact then Southern Water will attend in order to investigate. If, once on site, the location of the blockage is still unclear, attempts will be made to clear the blockage such that the area drains effectively. If the problem repeats, it will be at that point and in light of existing knowledge that responsibility may be identified. 

Can Southern Water take action where damage is caused by tree roots? 
Southern Water has statutory rights to protect its infrastructure where damage is being caused. This may involve removal of all or part of a tree which is causing that damage. However, this would be a last resort and would always be done in liaison with the property owner. In most cases root cutting and sewer relining would be carried out. 

If the problem is on a private drain will Southern Water clear it? 
Where we have made a commitment to the customer to attend to their incident and are on site when the blockage on the private drain is positively identified, we will offer to spend an additional 30 minutes trying to resolve issues on private drains. Southern Water will always give the customer the option of appointing their own contractor before starting any further work. We will provide customers with information about their ownership responsibilities and record that we have dealt with a private issue. If the customer contacts us in future and we attend site and find a private issue, they may be charged for our attendance, and any additional charges as raised by our contractor should the customer wish to instruct them directly. 

Can Southern Water take action against customers who abuse the sewers and drains? 
Southern Water has legal powers to deal with repeat offenders in commercial premises discharging trade effluent but for private properties our powers are more limited. It is hoped to deal with these through the ongoing education of customers as to what is appropriate to put down a public sewer, and what might cause unnecessary blockages, such as fabric material, wipes and nappies. 

How will Southern Water deal with access issues if the customer is not at home? 
The call centre will give the customer an estimated time of arrival and ask if this is convenient. If it is not, an alternative time will be agreed with the customer if the circumstances are not urgent. Our experience shows that in the case of sewer incidents 
customers prefer to be at home while we work on their property. If customers are not at home when we attend, or we have to carry out work in a neighbouring property 
our field agents will leave a “sorry we missed you” card with a summary of the work carried out and contact details for Southern Water. In matters where public health may be placed at risk, the courts will allow access to be made without the owners consent 
upon an urgent or emergency basis. 

What access rights do Southern Water have? 

In most instances the customer has contacted us and therefore access is not an issue. We have powers to access a property in the case of an emergency e.g. if the blockage is in the boundary of another property and there is a risk of the severity of the incident increasing. If a customer refuses entry Southern Water may rely upon its statutory rights of entry, which ultimately are enforced by obtaining a warrant of entry from the local Magistrates’ Court. 

If a Housing Association receives a complaint from a customer should they investigate it or advise the customer to contact Southern Water? 
Southern Water is aware that many tenants will report issues to their landlord in the first instance. We are happy for housing associations to carry out initial investigations to determine if the issue is on a public or private sewer. 

Can Southern Water provide information for our website? 
We suggest you provide a link to our website www.southernwater.co.uk which includes a section dedicated to the transfer of ownership of private sewers. 

Southern Water’s call centre can be frustrating to deal with, especially when Local Authorities or Housing Associations know what the problem is. 
The call agents in our new wastewater customer contact centre in Falmer have undergone intensive training to improve the quality of their call handling. They will also be trained to recognise callers from external organisations who do not need to be taken through the case based reasoning. Therefore, please make it clear at the start of the call where you are calling from. We hope you will see improvements in our call handling but would welcome any feedback. 

What happens if the sewer or drain is under a patio or decking? 
Our service providers will use trenchless technology to carry out investigations and repairs where ever possible. However, there may be occasions where the only solution is to dig up such areas. This will be carried out in consultation with the customer and we will follow our existing Codes of Practice concerning works on third party land. 

Do Southern Water have the power to enforce work on lateral drains? 
Yes, we have statutory powers to carry out work but because of our protocols we do not expect to have any significant issues with people refusing access to their land to repair lateral drains. 

Will Southern Water notify the Local Authority of issues on private drains? 
We anticipate working closely with Local Authorities on issues if a customer does not resolve an issue which is affecting other customers and if unresolved may cause pollution and other damage. 

If a row of housing is mixed ownership e.g. private and housing association, is there a risk that both Southern Water and the Housing Association will be 
called out? 
This scenario may happen but we would rather there are two responses to an incident than none. Each organisation should only work on the sewers and drains which are their responsibility but we appreciate that property owners may carry out investigations on Southern Water’s assets in order to determine responsibility for the issue. Repairs on the Section 105a sewers and laterals should only be carried out by Southern Water. 

Will Southern Water be able to escalate a call from within the call centre? 
Yes, we are recruiting a team of Customer Interface Agents (CIAs) across our region who will attend all priority 1 incidents alongside our service provider. Our team of CIAs, work dispatchers and call agents are all based in the new call centre facility at Falmer so lines of communication for escalating calls are much shorter than in the past. 

Will Southern Water be replacing pitch fibre pipes? 
Our Regulator, Ofwat, expects Southern Water to carry out “prudent investment” during the current investment period until 1st April 2015. Therefore, if pitch fibre pipes are causing serviceability issues such as blockages and sewer flooding we will look to carry out appropriate work, either repair or replacement of these sewers. There are no plans for a universal programme of replacement in the current investment period but this is something we may wish to request funding for from Ofwat in future 
investment periods. 

Will Southern Water carry out rat baiting? 

Southern Water has a responsibility under Section 2.1 of the Damage by Pests Act 1949 to eradicate rodents where they are known to be a nuisance in public sewers. We will therefore look to carry out rat baiting in any such areas. 

What priority will rodent issues have compared to other incidents e.g. flooding? 
Southern Water are tied by our regulator Ofwat to undertake prudent financial investment in the current investment period (2010-15). Unfortunately issues such as rodents will therefore be low priority compared to issues such as sewer flooding. 

If a customer contacts a private drainage contractor are they obliged to inform the customer that Southern Water could resolve it free of charge? 
No we are not aware of any legal requirement to do so, but the private contractor will be trespassing by working on Southern Water’s assets and that can give rise to criminal liability. We would always recommend that customers only use reputable 
contractors. 

What is the protocol for customers using their own insurance to cover repairs due to the failure of Southern Water’s assets? 
The causation of a flooding incident is not always clear at the time and prompt action often minimises damage which arises. If the customer has the benefit of an insurance policy, it is always strongly recommended that the customer contact the insurer. There may in fact be an obligation under the insurance terms to do so. In turn, their insurers may seek to recover their outlay from Southern Water should it become clear that we were responsible for the flooding in the first instance. This is not always the case, for example where the flooding is related to extreme weather conditions or some other non-negligent event occurs. 

Pumping Stations 

Will Southern Water take ownership of the gravity sewers upstream of a private pumping station? 
Yes, these sewers transferred ownership to us on 1st October. 

Will Southern Water take ownership of the rising main from a private pumping station? 
No, the rising main will transfer ownership at the same time as the associated pumping station. 

Will Southern Water take ownership of pumping stations which serve housing association properties? 
Yes, by 1st October 2016 we will take ownership of all pumping stations which serve two or more properties, or are outside the curtilage of a single property. Pumping stations serving multi-occupancy sites (a block of flats, caravan sites, industrial parks 
etc considered to be a single curtilage) will not transfer. Prior to transfer, pumping stations will have to be in a safe and serviceable condition. 

How can we report any information regarding private pumping stations to Southern Water? 
There is a form for customers to provide details on private pumping stations on our website. 

Who will pay for any work required on pumping stations which are not in a serviceable condition prior to transfer of ownership to Southern Water? 
The costs of pumping station upgrade will be covered by Southern Water. We are currently working to develop our strategy for private pumping station transfers but it is likely that pumping stations which are in serviceable condition, will be transferred early. 

Will the standards for future pumping stations change if they are all to be adopted by Southern Water? 
Standards for new pumping stations are covered by the water industry document ‘Sewers for Adoption’. An updated version will be published to coincide with 
the implementation of Section 42 of the Flood and Water Management Act, which will introduce the mandatory adoption of all new sewers and laterals. 

What will happen if a private pumping station failure causes an overflow from the upstream sewer network? 
The upstream sewers will most likely be the responsibility of Southern Water and we will therefore attend such incidents in order to determine if a private pumping station is the root cause of the issue. We will work to identify the pumping station owner and ensure they resolve any issues with the pumping station. If the current owner does not 
resolve the issues further action will be taken to ensure the situation is remedied. 

Will Southern Water adopt land surrounding pumping stations? 
In most cases Southern Water would wish to transfer land around transferred pumping stations. However, the most important issue is 24 hour access to deal with emergencies. If this can be achieved without transferring land, then land transfer 
may not be essential. 

Will Southern Water take ownership of maintenance contracts when they adopt the pumping station? 
No, there is no requirement for water and sewerage companies to take ownership of private maintenance contracts. 

Our Service Providers 

How will Southern Water operate with Clancy Docwra and Dyno-Rod in terms of work allocation? 
Our customer contact centre will use case based reasoning to try and determine from the customer if their issue is on a Section 105a or a former public sewer. This includes a question on the age of the property (pre- or post-1937). Based on the response to this the appropriate service provider will be allocated the work. If the “wrong” contractor attends an incident they will resolve the issue where ever possible. 

Past experiences with Dyno-Rod have not been positive, how were they selected? 
Dyno-Rod was selected through a process of competitive tender. Each tender was scored against a number of pre-defined metrics with a primary focus on technical capability and customer service skills. 

What ID will Dyno-Rod carry? 
Dyno-Rod field agents will carry Southern Water ID cards as well as the relevant letters of authority for access etc. All field agents will wear dual branded clothing with the Southern Water and Dyno-Rod logos. The vans will be white and carry both logos. 

What capability will there be on the Dyno-Rod vans e.g. are they one or two man vans? 
The first response vehicles are all one man vans. On arrival at the point of works a risk assessment will be carried out to determine if another person is required. The second attendee at site may be a tier two “orange” van if all Southern Water Dyno-Rod vans are engaged elsewhere. 

Will Dyno-Rod have a team based on the Isle of Wight? 
Yes, there will be 2 first response vehicles based on the Isle of Wight, as well as access to 2 Dyno-Rod “orange vans” and a repair vehicle. 

Are Dyno-Rod’s field agents working on commission? 
No, Dyno-Rod’s field agents are dedicated to the Southern Water contract and will have no ability to offer other services to customers or take payment from them. They are all salaried and are not working on any commission basis. 

Will Dyno-Rod’s field agents work on other Dyno-Rod jobs? 
No, Dyno-Rod’s field agents are dedicated to the Southern Water contract. 

How long is Dyno-Rod’s contract for? 
Dyno-Rod’s contract is for 4 years with the option of a 3 year extension period. 

Will Dyno-Rod use fire hydrants for jetting or the customer’s metered water supply? 
Fire hydrants and stand pipes will be used for jetting purposes. These are ¾” standpipes which are designed not to disturb the water supply in the area. 

How many engineers will Dyno-Rod employ? 
Dyno-Rod will employ around 70 engineers on the Southern Water contract who will be based at depots across our region. 

What does Dyno-Rod’s clean-up procedure consist of e.g. for external flooding? 
Dyno-Rod apply the WRc procedures for the cleanup of sewer flooding. This involves raking up any solids and disinfecting hard standing areas. Southern Water are aware that customers are often not happy with the guidance given on UV disinfection on areas such as flower beds which can not be disinfected and alternative approaches are 
being considered. We will always try to carry out the clean-up during the first response visit. However, there will be occasions when this is not possible e.g. additional equipment is required or the time of day or weather conditions make this impractical. 

Can Dyno-Rod sub-contract? 
Yes, Dyno-Rod will have a core team of field agents to deal solely with Southern Water’s first response calls. At times of high demand they will call upon additional resources according to their tier structure of franchises and sub-contractors. 

Will Dyno-Rod be able to carry out repairs? 
Yes, Dyno-Rod has repair vans dedicated to this contract and can call on additional resources from their company managed operations, franchises and sub-contractors. One of their specialist areas is reforming and relining and they have several patented systems. 

Do Dyno-Rod have access to “bigger” vehicles e.g. to deal with deep or large diameter sewers, if the first response vans are unable to resolve the issue? 
Yes, if the first response or repair vans are unable to resolve an issue then Dyno-Rod have access to larger vehicles such as tankers as required. 

New Developments and Build Overs 

When will sewers on new developments be adopted? 
Any sewer “communicating” i.e. has flow running through it, with the public network before 1st July 2011 transferred ownership to Southern Water on 1st October. From a date still to be determined by the Government (likely to be 1st April 2012) the Flood & Water Management Act (FWMA) 2010 will require new developments to have a Section 104 agreement and be constructed to a mandatory build standard. Hence, there will be a “gap” of sewers built between 1st July 2011 and the date from which the mandatory build standard comes into force. These sewers will be adopted in a supplementary transfer, expected to be 1st October 2012. Please note these are dates 
are subject to change as the legislation has yet to be enabled. 

If there is already a Section 104 agreement in place before the change in legislation will this remain valid? 
Any live gravity sewers communicating with the public sewerage system before 1st July 2011 transferred to Southern Water on October 1st 2011. Other assets covered in the S104 agreement, but not covered by the October 1st transfer (wastewater treatment works, pumping stations, surface water sewers discharging direct to the environment) will transfer in accordance with the terms of the S104 agreement. Gravity sewers which communicate with the public sewerage system after July 1st 2011 will be transferred in the supplementary transfer referred to above. 

What impact will Building Control have over new developments? 
Developments will still have to comply with Part H of the Building Regulations as well as having Water Industry Act (WIA) 1991 Section 104 and 106 agreements in place. 

When will Sewers for Adoption 7 be published? 
Sewers for Adoption (SFA) 7 will not be published until the Mandatory Build Standards are issued. An addendum to Sewers for Adoption 6 which contains many of the proposed changes can be obtained in advance by ordering SFA7. 

Are developers able to reserve capacity in a Section 104 agreement? 
No, capacity is assigned on a first come first served basis and can not be reserved. 

Does this change the standards developers should be designing to at present? 
No, until Sewers for Adoption 7 and the mandatory build standards come into force, developers should still use part H of the Building Regulations and Sewers for Adoption 6. 

Can private drains be offered for adoption earlier? 
Yes, providing they have been built to adoptable standards, developments completed after 1st July can be offered for adoption prior to the supplementary transfer date. 

Is Southern Water going to increase their resources to deal with the increase in workload once Section 104s become mandatory so as not to delay developments? 
Yes, we will be increasing our resources to deal with Section 104 applications. We would also encourage Developers to talk to us early in the planning process regarding the proposed drainage layouts so as to resolve any issues early in the process and prevent delays when the Section 104 is submitted. 

How long will it take for a Section 104 to be approved? 
Timescales for the approval of a Section 104 have not yet been agreed as we are still working to clarify the requirements of future S104 adoptions. This will be confirmed once dates for the new legislation coming into force are more certain. 

Will new developments be required to have the drainage running round the front of the properties? 
There is a strong preference for drainage at the front of properties, so that access for maintenance is more straightforward. Sewers for Adoption 7 will set out preferred layouts. However, Sewers for Adoption provides guidance, and alternative layouts may be permissible in certain circumstances. We would encourage developers to talk to us about their proposed drainage layout early in the planning process to prevent delays further in the process. 

What will the requirements for easement strips be? (concern that this will affect the layout of future developments)? 

The requirements for easements will be defined in Sewers for Adoption 7 and have reduced clearances for smaller diameter sewers. These are similar to Part H of the Building Regulations. 

Will agreement drawings have to show these sewers in future? 
Yes, the sewers and laterals which will be adopted by Southern Water will need to be included on the as built drawings. The criteria for these drawings will be defined in Sewers for Adoption 7. 

How will the change in legislation affect multi-phased development sites which are constructed over a number of years? 
The legislation will apply as for all sites – any phases which communicate with the public sewer network before 1st July 2011 transferred ownership automatically to Southern Water on 1st October. Any future phases (after 1st April 2012) will require a 
Section 104 and Section 106 agreement to connect to the public sewer. 

If a single property with private drainage connects a new property to their drainage will this become public from the point at which it serves both properties? 
No, this will not automatically become a public sewer. The legislation applies to the layout of sewers before 1st July 2011. However, customers in such cases could apply to Southern Water to adopt the sewers. 

What will happen with build overs if Section 105a sewers are not shown on the public sewer map? 
WaterUK is developing a draft protocol which water and sewerage companies may use to clarify how these sewers are dealt with by local authority Building Control Officers. At present small diameter, shallow public sewers are generally dealt with by 
Building Control Officers using powers delegated to them by Southern Water. Until a protocol is in place the existing process should continue to be used. Building Control Managers are requested to notify Southern Water if larger, deeper sewers are 
encountered, or if access is likely to be difficult if the development proceeds. 

What should Local Authorities do regarding build overs in terms of extensions already built or those proposed? 
Southern Water asks that Building Controls teams continue to execute their duty of care over public sewers and make a judgement. We are working on a new protocol on this issue which will be shared with Local Authorities. 

Will all water companies apply the change in legislation in the same way for new developments? 
In terms of legal requirements all water companies should be consistent but as Sewers for Adoption is only for guidance rather than regulatory purposes there may some difference in the interpretation of this guidance. 

Will manholes on extensions be required to be within the property curtilage? 
No, not necessarily. Access to public sewers needs to be provided within reason and in agreement with customers. So long as there is sufficient access this does not have to be within the property curtilage. 

If a lateral is under a dwelling will the householder have to install a manhole cover? 
No, so long as there is sufficient access e.g. for jetting, then a new manhole may not be needed. If Southern Water has repeat call outs to a property with insufficient access then we may install a new inspection chamber to determine or resolve the 
cause of the issue. 

What should Developers do if they aren’t sure what has / hasn’t been adopted by Southern Water? 
Southern Water will be happy to review plans of ongoing developments with developers if there is any clarification required over sewer ownership. To discuss specific issues relating to future adoptions, please contact the Network Developments Team in Winchester. 

What will happen if a Developer wishes to abandon a sewer e.g. to redevelop an existing site? 
If a developer wishes to either divert or abandon a public sewer they will need to apply through the usual process for either a S104/185 or a stopping-up agreement. To discuss specific issues relating to future adoptions, developers should contact the 
Network Developments Team in Winchester. 

Will bonds increase if Southern Water is going to adopt more sewers than previously? 

Bond arrangements are being discussed in the industry at present and are likely to change because of the legal obligation to adopt all new sewers and laterals, whether or not they comply with the agreed S104. Various options are being considered as the 
water industry appreciates that larger bonds may not feasible for many developers. Options which are being discussed include security arrangements rather than bonds, and a scheme of certified ground workers. 

Will there be an increase in supervision fees? 
Any increase in supervision fees is still under discussion in the industry and as yet there is no conclusion on the matter. This will be detailed in Sewers for Adoption 7. 

If there are multi-occupancy sites within a single curtilage which are not adopted by Southern Water who will take responsibility for repairs etc if there is no single owner or management company? 
Such sites are not included in the automatic transfer of ownership on 1st October and if there is no single owner these may be contested in law. There is also a right to appeal to Ofwat in future if customers consider that their sewers should have been 
adopted (Section 94 Water Industry Act 1991). 

What should Developers do if constructing on a public sewer site and find that work needs carrying out e.g. root cutting, patch lining? 
Southern Water should be informed of any such issues identified on development sites. Please contact the Network Developments Team in Winchester. 

Who will be the SuDS Approval Body? 
Southern Water has generally not adopted SuDS systems in the past. Under the Flood and Water Management Act 2010 (S32) The County and Unitary Councils will be responsible for approving and adopting SuDS although this change in legislation has not yet been enabled. It is expected that consultation on the Regulations will take place early in 2012, for the legislation to be enabled in October 2012, although this is not certain at present. 

Will Southern Water have a duty to adopt sewers on new developments within a certain timescale, and if so, what is this? 
Yes, it is anticipated that the Flood and Water Management Act will clarify any future adoption requirements. 

Will the water companies become statutory consultees? 
Water companies are statutory consultees for local authority planning processes, but not for individual planning applications. We are however consulted for sites above a given size (typically 20 properties). Water companies will be statutory consultees for 
SuDS if the SuDS is proposed to connect to the public sewerage system. 

Will the 1 year maintenance period still apply? 
We are unsure at this time as this will be clarified in the Floods & Water Management Act 2010 and Sewers for Adoption 7. 

Will Southern Water inspect sewers which will in future become public, and do they have the resources to do this? 
Yes, we will carry out inspections and will be increasing our resources to manage the increase in workload. 

Will Southern Water take over responsibility from building inspectors? 
This is still to be determined. We are working on a new protocol for this which will be shared with Local Authorities. 

Will all new developments be required to include sustainable drainage? 
In future all new developments will be required under the Floods and Water Management Act 2010 to include sustainable drainage. This is likely to come into force from October 2012 and may be phased e.g. by largest developments first. New 
developments will not be able to connect to the public sewer network after this date unless they include sustainable drainage. 

Will Southern Water notify developers to confirm sites which have been vested or should developers apply to Southern Water? 
Southern Water requires one notice for legal vesting purposes. Developers need to advise Southern Water on what was connected to the public network on 1st July 2011 in order to release the bonds.