Publication

It is therefore suggested that point 9 of Policy 2 be amended to be effective and justified as follows:
‘Minimise flood risk, including Support [efficient] [text to be deleted] [integrated] [new word] water management. Flood risk should be minimised, including avoiding inappropriate development in areas at significant risk of flooding, reducing the causes and impacts of flooding, supporting a catchment approach to water management and using sustainable [drainage systems as part of all development proposals.] [new text] Development must also protect water quality, both surface and groundwater, and be water efficient [and make use of water-reuse measures wherever feasible.] [new text] To achieve the latter:

It is therefore suggested that point iv of Policy 2 be amended to be effective as follows:
‘Potential applicants for planning permission for major developments are advised to contact Anglian Water Services in the early stages of producing a development scheme in order to ensure that there is adequate capacity, or capacity can be made available, in the [wastewater] [word to be deleted] [sewerage] [new word] network [and at the receiving water recycling centre.] [new text]The provision of capacity could affect the timing of development. In locations where there are known to be capacity issues the local authority will expect this engagement to have taken place and for it to be demonstrated that adequate capacity will be available to serve the development (see Appendix 1 Infrastructure Requirements for currently known locations with capacity issues)’

Point 9: Policy 2 refers to residential developments being required to mininise water consumption by meeting the optional requirement of 110 litres/per person/per day.

Anglian Water, the Environment Agency and Natural England has issued advice to local planning authorities (copy attached) stating that there is evidence to demonstrate a need for optional water efficiency standard to be applied in the Anglian Water supply area. As such we fully support the inclusion of this standard in the policy.

We fully support the intention that development proposals will be expected to meet the current standard water efficiency rather than be limited to the existing standard. This is particularly important given Defra’s recent consultation on personal consumption of water which included reference to potential changes to existing building regulations on water efficiency.

Anglian Water is keen to promote the development of ‘Water smart communities’ including as part of the Local Plan. They use a more holistic and integrated approach to water management with the aim to:

• Enhance liveability by contributing to green streetspaces and high quality open space
• Promote the sustainable use of water resources and infrastructure to enable growth
• Build resilience against the impacts of climate change and extreme weather events
• Contribute to natural capital and biodiversity through multi functional water features
• Deliver water efficient homes to reduce household bills and support affordability

Opportunities for a more holistic and integrated approach to water management should form part of the plan, to encourage multi-functional water management assets which support other community objectives. This approach combines different elements of water management (e.g. combining SuDS with a water re-use system to both manage runoff and provide an alternative non-potable water supply) together with town planning and design (e.g. integrating the planted SuDS features throughout a development to contribute to ‘greener’ streetscapes). This would also be consistent with the justification given for provided for the requirements relating to water use which reference greywater recycling and rainwater capture (Table 8 of the plan).
We note that Policy 2 has been amended following the previous consultation but that our suggested changes relating to integrated water management including the use of SuDs (as the preferred method of surface water management) and water re-use measures is not included.

Point iv: in our previous comments we had also sought the inclusion of reference to foul drainage and sewage treatment which appeared in an earlier version of Local Plan (as part of Policy FR1). We are generally supportive of the wording as proposed but would make the point that the term ‘wastewater network’ is not defined and Appendix 1 refers to water recycling centres as well as the wastewater (sewerage) network .

Anglian Water supports the requirement to provide 10% biodiversity net gain for developments in the Greater Norwich area having followed the mitigation hierarchy.

To be effective it is suggested that the final sentence be removed from paragraph 256.
It is therefore suggested that paragraph 256 be amended as follows to ensure it is effective:
‘Funding for water infrastructure improvements is provided through developer charges directly for connections to water supply network and foul sewerage networks. [Taking account of the above evidence, the policy therefore commits the Greater Norwich authorities to lobbying for the timely delivery of improvements to the waste -water network by AW.] [text to be removed]’

Para 256 – Policy 4 has been amended to take account of our previous comments relating to lobbying of utility companies. However the supporting text still refers to lobbying Anglian Water in respect of improvements to the wastewater network.

It is therefore suggested that Paragraph 257 is amended to ensure it is justified and effective as follows:
‘To ensure that development does not have a detrimental impact on the water environment, particularly in relation to water quality and the potential for impacts on the water-based sites protected under the Habitats Regulations Directive, major development will be dependent on the water [recycling] [new word] infrastructure being capable of accommodating the development or being able to be made so.’

Para 257 - Reference is also made to water infrastructure being capable of accommodating development or being able to be made so to ensure that there isn’t a detrimental impact on water environment particularly in relation to water quality. However, the Habitats Regulations Assessment does not identify an adverse effect on the integrity of Natura 2000 sites assuming that capacity at water recycling centres is addressed. It is therefore suggested that the text should refer to water recycling centres and not water infrastructure more generally.

Anglian Water is the land owner of Site R31: Heigham Water Treatment Works, Waterworks Road which is allocated for housing in the adopted Norwich City Site Allocations Plan. We continue to support the allocation of this site for housing as it is both available and deliverable within the plan period of the new Local Plan.

Savills will be making a separate response in relation to the above site on behalf of Anglian Water.

Add new paragraph to supporting text to read:

There is an existing foul and surface water sewer in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take these into account. This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewers should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing assets may be required

There is existing foul and surface water sewers within the boundary of the site. We would ask that this be considered as part of the site design and layout to ensure that we can continue to serve our customers. In the event that there is a need to divert our existing assets a formal application to Anglian Water would be required.

Add new paragraph to supporting text to read:

There is an existing foul sewer in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take these into account. This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewers should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing assets may be required.’

Add new criterion to Contingency Site Policy GNLP0596R:
‘the safeguarding of suitable access for the maintenance of foul drainage infrastructure.’

There is existing foul within the boundary of the site. We would ask that this be considered as part of the site design and layout to ensure that we can continue to serve our customers. In the event that there is a need to divert our existing assets a formal application to Anglian Water would be required.

Add new paragraph to supporting text to read:

There is existing water mains and a surface water sewer in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take these into account. This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing water mains and surface water sewer should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing assets may be required.’

Add new criterion to Contingency Site Policy GNLP2018:
‘the safeguarding of suitable access for the maintenance of foul drainage infrastructure

There is existing water mains and surface water sewer within the boundary of the site. We would ask that this be considered as part of the site design and layout to ensure that we can continue to serve our customers. In the event that there is a need to divert our existing assets a formal application to Anglian Water would be required.

POLICY GNLP0451
There is existing foul within the boundary of the site. We would ask that this be considered as part of the site design and layout to ensure that we can continue to serve our customers. In the event that there is a need to divert our existing assets a formal application to Anglian Water would be required.

Add new paragraph to supporting text to read:

There is an existing water main in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take these into account. This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewers should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing assets may be required.’

Add new criterion to Policy GNLP2136:
‘the safeguarding of suitable access for the maintenance of water supply infrastructure

There is existing water main within the boundary of the site. We would ask that this be considered as part of the site design and layout to ensure that we can continue to serve our customers. In the event that there is a need to divert our existing assets a formal application to Anglian Water would be required.

Add new paragraph to supporting text to read:

There is an existing water main and foul sewer in Anglian Water’s ownership within the boundary of the site and the site layout should be designed to take these into account. This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing sewers should be located in highways or public open space. If this is not possible a formal application to divert Anglian Water’s existing assets may be required.’

Add new criterion to Policy HAR 4:
‘the safeguarding of suitable access for the maintenance of water supply and foul drainage infrastructure

There is existing water main and foul sewer within the boundary of the site. We would ask that this be considered as part of the site design and layout to ensure that we can continue to serve our customers. In the event that there is a need to divert our existing assets a formal application to Anglian Water would be required.