GNLP 2045 Regulation 20 Scoping Consultation

Please see our response to Question 1.

Anglian Water is the statutory water and sewerage undertaker for the Greater Norwich Local Plan area and a statutory consultee in the preparation of local plans. We welcome the opportunity to comment on the scope of the Greater Norwich Local Plan 2045.

Water resources, wastewater infrastructure, flood resilience, water quality and the natural environment are closely connected to the location, scale, design and phasing of growth. We therefore welcome continued early engagement with the Greater Norwich authorities as the spatial strategy, evidence base, site allocations and local policies are developed.

Anglian Water broadly supports the initial SWOT analysis, including the identification of infrastructure delivery, threats from climate change impacts, positive environmental impacts and opportunities arising from sustainable and resilient growth, and infrastructure investment. We recommend that the following matters are made more explicit.
Strengths
• Established joint working between the Greater Norwich authorities, infrastructure providers and other public bodies provides a strong basis for coordinating growth, infrastructure investment and environmental improvements.
• Existing strategic water, wastewater and green infrastructure networks provide a foundation for sustainable growth, where capacity and environmental constraints are properly assessed.
• Greater Norwich has significant opportunities to integrate blue and green infrastructure, sustainable drainage systems, and water management into new development.
• The concentration of growth at strategic locations can provide the scale and longer lead-in periods necessary to plan and deliver efficient infrastructure solutions.
Weaknesses
• Capacity within wastewater networks and at water recycling centres is not uniform across the Greater Norwich area. Available capacity can also change over time because of new connections, weather conditions, infiltration, changes to environmental permits, operational optimisation and infrastructure investment.
• Surface water entering foul or combined sewer networks can reduce network capacity, increase flood risk and contribute to storm overflow operation. Investigations to reduce storm overflow spills have been identified in Asset Management Period 2025-2030 (AMP8), and also schemes to reduce high spilling storm overflows to less than 10 spills per year. Any investigations carried out in AMP8 may identify and subsequently inform the scope of improvement actions in AMP9 (2030-2035).
• Development patterns, particularly dispersed rural development, can make infrastructure improvements more costly, carbon intensive and difficult to coordinate.
• Water availability for large non-domestic users may constrain some forms of commercial and industrial development unless water efficiency, alternative supplies and non-potable reuse are considered from the outset.
Opportunities
• Directing growth towards locations with existing infrastructure capacity, or where infrastructure can be delivered efficiently and in step with development.
• Using strategic development and any new settlements to deliver integrated water management, including highly water-efficient buildings, rainwater harvesting, greywater reuse, multifunctional SuDS and sufficient land for infrastructure.
• Retrofitting SuDS and green infrastructure within existing urban areas and brownfield sites to reduce surface water entering sewer networks and provide wider biodiversity, amenity and climate-resilience benefits. This aligns with measures outlined in the Norfolk Local Nature Recovery Strategy supporting catchment-based initiatives to coordinate nature recovery, water quality, flood management and low-flow improvements.
• Supporting renewable and low-carbon energy generation associated with water and wastewater infrastructure through positive and flexible criteria-based policies.
Threats
• We recognise that water scarcity arising from climate change, population growth, environmental abstraction reductions, and wastewater network or treatment constraints can be threats where the scale and timing of growth are not aligned with infrastructure investment. The emerging Drainage and Water Recycling Management Plan (DWMP28), Water Resources Management Plan (WRMP29) and future water company business planning cycles from 2030, will take account of the uplift in housing requirement for the Greater Norwich authorities. We will continue to liaise with local planning authorities throughout the preparation of these key documents alongside the local plan.
• Significant climate change impacts, including increased risk of drought, and flood risk from all sources, including surface water, sewer flooding and the effects of more intense rainfall. Climate change impacts are factored into the development of our DWMP and WRMP.
• Development encroaching on operational water and wastewater assets, potentially affecting the amenity of future occupiers and restricting the maintenance or future expansion of essential infrastructure.

Anglian Water's Blueprint for Growth sets out how water infrastructure, investment and regulatory change can unlock and support sustainable economic and housing growth in the East of England.

Yes. Anglian Water supports the proposed structure for GNLP 2045. The proposed digital and map-based approach should assist in identifying the relationship between development, environmental constraints and infrastructure. We recognise that the publication of the new National Planning Policy Framework (NPPF) in August 2026, will mean there are likely to be limited local policies due to the new National Decision Making Policies (NDMPs).

The concentration of a significant proportion of growth in and around Norwich and in larger settlements can support more efficient infrastructure provision than a widely dispersed pattern of development. Larger strategic sites can also provide sufficient scale and lead-in time to plan infrastructure across more than one water company investment period.
The settlement’s position in the hierarchy does not demonstrate infrastructure capacity is available. The accessibility and sustainability of a location must be considered alongside supporting evidence such as the Water Cycle Study, Strategic Flood Risk Assessment, and Infrastructure Delivery Plan.

How can the GNLP 2045 support the development of brownfield sites?
Brownfield development can make efficient use of land in sustainable urban locations. However, prior development does not necessarily mean that drainage and wastewater infrastructure has sufficient capacity for a new or more intensive use. The opportunity to remove existing surface water flows from combined or foul sewers should be treated as an important infrastructure and regeneration benefit.
What development types would you support as part of the updated Growth Strategy?
Anglian Water would support a balanced combination of:
• urban and brownfield regeneration;
• sustainable extensions to larger settlements;
• appropriately phased strategic sites;
• appropriately scaled new settlements where infrastructure is demonstrably feasible and viable; and
• proportionate rural growth where there is sufficient infrastructure capacity and no overriding environmental constraint.

STRATEGIC SITES:
Anglian Water has recently shared with local planning authorities, our guidance note on strategic sites (500+ homes) as we recognise that certain sites, while having more limited existing capacity at our water recycling centres and within our wastewater networks, remain sustainable in wider planning terms and important contributors to housing need. Therefore, these strategic sites may appropriately come forward over a longer time horizon as infrastructure investment is identified and delivered over subsequent asset management periods (AMPs).

In such cases, a phased approach to strategic sites allocated in a Local Plan would enable us to plan and deliver any required infrastructure investment in a timely and coordinated manner, ensuring our existing customers and the environment are protected. Given the scale of these sites, we fully appreciate that the build-out of strategic sites will occur over an extended period, with phased connections to the wastewater network. It is recognised that delivery of strategic sites could span several asset management periods (AMPs - five-year investment cycles), allowing development trajectories to inform future business planning and investment strategies. Anglian Water is, therefore, supportive of the principle of development at sustainable locations. However, to ensure that connections are appropriately phased and environmentally robust, we will recommend that appropriate planning conditions are imposed, so development is phased with in step with delivery of the required sewerage/drainage infrastructure.

Anglian Water would also expect a robust strategy for integrated water management on strategic sites to ensure that the most efficient use of water resources can be facilitated through the reuse of surface water run-off attenuated by SuDS and/or grey water reuse.

We are currently working with government and stakeholders on developing a process to provide a consistent framework for seeking options and solutions to managing wastewater constraints that are impacting development. The aim is to help bring forward smaller sites where there are existing capacity constraints at our WRCs and wastewater networks. Updates on this process will be shared as the local plan progresses.

NEW SETTLEMENTS
New settlements should be of a scale where it is feasible and viable to provide on-site infrastructure, particularly if they are located in areas where existing infrastructure networks, e.g. for wastewater conveyance/treatment, are not currently available. There are options available for wastewater infrastructure delivery but this would be wholly dependent on the location of the new settlement, its scale, and whether there are specific environmental capacity constraints that might inform potential infrastructure delivery solutions. This should be aligned with broader opportunities for embracing a circular economy and sustainable water management – through incorporating integrated water management measures from the outset to help deliver water smart communities. The quantum of growth will be a key factor in assessing viability and feasibility of infrastructure delivery, and will inform the spatial strategy and housing trajectory, given longer lead-in times to starting construction on site.
The options for delivering an on-site WRC are:
1. Developer delivers onsite WRC - designed to Anglian Water (AW) specifications - AW would adopt WRC and operate following a defects liability period.
2. Developer uses a NAV (New Appointments and Variations) to deliver and operate the new infrastructure on site including WRC.
3. Anglian Water delivers the infrastructure onsite - this would be subject to the DWMP informing future investment schemes, and funding being agreed by our regulator.
In all circumstances sufficient land would need to be safeguarded for the WRC and encroachment buffer to avoid impacts on sensitive receptors. A suitable discharge point and permit considerations would need to be discussed with the Environment Agency. Options 1 and 2 would be funded by the developer, not AW, unless alternative funding sources are identified.
For strategic site allocations, the plan should provide sufficient site-specific detail on infrastructure, phasing, integrated water management, asset protection and requirements for early engagement. An infrastructure schedule linked to the digital policies map would help make responsibilities, interdependencies, delivery triggers and monitoring outcomes transparent. Masterplans should be required for strategic sites/new settlements and demonstrate engagement with key stakeholders (including utility providers) in their preparation, prior to being submitted as part of a planning application for a site. This will requires developers to seek early engagement to ensure that appropriate measures are taken on the concept design/layout with regard to infrastructure requirements, SuDS/surface water drainage opportunities, any existing infrastructure within the site, and potential asset encroachment matters.
Village-cluster growth may be appropriate where sufficient infrastructure capacity exists and the development is otherwise sustainable. However, a highly dispersed strategy can require disproportionately extensive infrastructure for a relatively small amount of growth.

At this early stage, Anglian Water does not endorse a specific additional growth location. The appropriate distribution should be established through the Water Cycle Study or Integrated Water Management Study, Strategic Flood Risk Assessment, Strategic Environmental Assessment, and Infrastructure Delivery Plan.
We recommend prioritising locations where:
• there is existing wastewater treatment and network capacity, or a realistic and fundable pathway for providing it;
• where necessary, the development can be phased with infrastructure delivery;
• flood risk from all sources can be safely managed – including through multifunctional SuDS and blue-green infrastructure;
• water demand can be minimised through tighter water efficiency standards, and integrated water management incorporated from the outset;
• development would not unacceptably encroach on our operational infrastructure;
• sufficient land can be safeguarded for any required new or expanded infrastructure; and
• environmental permit requirements can be satisfied.
The current information available to Anglian Water on the AMP8 growth scheme for Whitlingham WRC is principally based on known adopted-plan growth. Future requirements/options will need to be reassessed through our emerging DWMP (2030-2055) once the emerging spatial distribution and growth trajectories are clearer.

The hierarchy should remain primarily place-based but should be informed by a transparent infrastructure and environmental assessment. It should not be based solely on population, service provision or transport accessibility.
Additional considerations:
• including infrastructure capacity and environmental resilience as explicit considerations;
• distinguishing between settlements with existing infrastructure capacity and settlements where growth depends on major reinforcement;
• recognising that some strategically sustainable locations may be capable of accommodating growth over a longer period through phased infrastructure delivery;
• avoiding uniform percentage increases across lower-tier settlements without assessing cumulative infrastructure impacts; and
• ensuring neighbourhood-plan housing requirements are consistent with strategic infrastructure evidence.
This would not make existing infrastructure capacity an absolute constraint. Instead, it would ensure that the hierarchy and growth trajectory can help to identify where future investment, phasing or alternative solutions/options will be required.

Anglian Water has no objection in principle to retaining locally specific guidance for self-build and custom-build housing, rural building conversions, replacement dwellings, subdivision and dwellings connected with rural enterprises, where this adds useful local clarity and does not duplicate national policy. Incremental rural growth can have a material cumulative effect where small settlements have limited sewerage infrastructure (see our Descriptive Works Position Statement). Policy requirements could ensure that development outside settlement limits has appropriate safeguards in place to ensure that there is capacity to accommodate wastewater flows at receiving wastewater networks and water recycling centres, or that private wastewater treatment proposals comply with the relevant environmental requirements. https://www.anglianwater.co.uk/siteassets/developers/new-content/p--c/descriptive-works-position-statement-march-2025.pdf

The GNLP 2045 should provide flexible, criteria-based policies for commercial development while recognising that different sectors have very different water demands, wastewater, energy and drainage requirements.
Anglian Water's Non Domestic Water Requests Policy (updated June 2026) explains that if new or extended requests for non-domestic supplies are received, which exceed 20,000 litres per day (20m3/day), developers will need to work with us to ensure developments are applying the water use and water re-use hierarchies. This will include highly efficient water use and alternatives to potable water use wherever possible. As a last resort, Anglian Water may need to decline the request for more water, in order to protect existing supplies and the environment.
With many areas subject to limits on new non-domestic demands, alongside abstractions from the environment being curtailed, there's a risk to a lack of available water. Without alternatives, this could undermine industrial development and decarbonisation. We are exploring opportunities for non-potable water reuse, through an independent study commissioned by the National Framework for Water Resources. The working group’s findings will feed into development of the updated National Framework for Water Resources and its ongoing implementation, being led by the Environment Agency. Further information on non-potable reuse opportunities can be found here.
We would welcome policies in the GNLP that:
• require early engagement with Anglian Water for major or water-intensive commercial development;
• require highly efficient water use (see the Shared Standards in Water Efficiency for Local Plans); and
• encourage non-potable water networks, rainwater harvesting, process-water reuse and circular-economy approaches.

Infrastructure delivery should be coordinated through an up-to-date Infrastructure Delivery Plan linked to the development trajectory and site-allocation policies.
The approach should include:
• early and continuing engagement with infrastructure providers;
• identifying critical dependencies, lead-in times and responsibilities;
• allocation-specific infrastructure requirements;
• phasing policies and planning conditions where development depends on reinforcement;
• where necessary safeguarding land and access for new or expanded infrastructure;
• recognising dependencies between infrastructure sectors, such as electricity upgrades required for WRC investment.
Water and wastewater infrastructure is principally funded through developer infrastructure charges for network connections and reinforcement, together with customer-funded investment approved through Ofwat’s five-year price-review process. Local Plan preparation does not itself guarantee water company funding. The Local Plan spatial strategy setting out a sustainable distribution of growth, is therefore essential so that any future infrastructure needs can be considered through the DWMP, WRMP and future business plans.
Strategic sites may build out over several investment periods. Where they are otherwise sustainable, a phased approach can allow development trajectories to inform future investment while ensuring that existing customers and the environment remain protected.