GNLP 2045 Regulation 20 Scoping Consultation

Anglian Water supports the intention to prepare a Water Cycle Study (WCS) to assess wastewater treatment capacity and sewerage network capacity taking account of existing commitments and proposed growth cumulatively within each WRC catchment. The WCS should consider current permits, planned investment and anticipated nutrient-removal requirements, and identify where growth can be accommodated, where reinforcement is required and where environmental permit constraints may limit options. This will help to establish allocation-specific phasing where future investment is required to accommodate growth.

We recommend that WRC headroom is assessed using an agreed and consistent methodology with the EA, Anglian Water and IDB. Anglian Water’s current plan-making approach uses the average measured dry weather flow Q80 data over the most recent five-year period for which reliable data is available. The findings should be treated as a snapshot rather than a fixed development ceiling because headroom is affected by several variables, including weather, new connections, water efficiency, permit changes and future upgrades.

Key policy recommendations include requiring development proposals to demonstrate that capacity is available, or can be made available, in the sewerage network and at the receiving water recycling centre to accommodate wastewater flows from the site.

We will identify sustainable points of connection into our networks by using a complexity matrix that presents a number of factors for assessment including pollution risks and storm overflow spills, surcharges of our network, existing flood potential and excess surface water flooding. The identification of a sustainable point of connection will be reflected in our planning responses and specified in a recommended planning condition.

Relevant WRCs serving nutrient-sensitive catchments (The Broads SAC and River Wensum SAC) will be required to meet technically achievable nutrient limits for phosphorus (0.25mg/l) and nitrogen (10mg/l) – through the LURA requirements by 31 March 2030, and any additional AMP8 WINEP drivers. Where a permit is set at TAL for phosphorus/nitrogen, increasing permitted dry weather flow (DWF) may be more difficult, although this does not mean that every WRC subject to tighter limits will lack DWF headroom. Collaborative working with key stakeholders to identify options such as catchment-based solutions and careful phasing will therefore be important. We endorse maintaining close joint working between the GNLP authorities, Anglian Water, the Environment Agency and Natural England.

Future investment in wastewater and drainage infrastructure is informed by our Drainage and Water Recycling Management Plan (DWMP). The Environment Act 2021 has made the preparation of DWMPs by water and sewerage companies a statutory requirement, and our next DWMP (due to be published in 2028) will be prepared under updated guidance published in May 2025, based on lessons learned from the first cycle of plans and the legal requirements now in place. The next DWMP must set out how we will manage and develop our drainage and sewerage systems to meet our obligations under Water Industry Act 1991. As with the Water Resources Management Plan (also in preparation for publication in 2029), this includes understanding how to deal with challenges such as asset health, climate change and population growth. Using this information, we conduct a risk assessment for three different timescales: the short- (5yr), medium- (15yr) and long-(25yr +) term. The outputs from these allow us to develop ‘best value’ investment solutions to meet our obligations in subsequent Price Reviews.

Water efficiency
Yes. The GNLP 2045 should set the most demanding locally justified standard that is feasible and viable, consistent with The Shared Standards for Water Efficiency in Local Plans, which is referenced in the Norfolk Strategic Planning Framework (Sept 2025) and recommends:
• a residential design standard of up to 85 litres per person per day where justified;
• full credits under the BREEAM water calculator for new, extended or redeveloped non-domestic development; and
• water-saving and water-reuse measures in major non-domestic development.
If the evidence or viability assessment does not support 85 litres per person per day across all development, the authorities should consider an intermediate standard, such as 90 or 95 litres, rather than defaulting to the minimum national requirement. Local standards should be supported through the Water Cycle Study and plan-wide viability assessment.
The policy should also encourage rainwater harvesting, greywater reuse and community-scale non-potable systems, particularly on strategic sites.
Tighter water efficiency standards can be justified under NPPF Policy PM13 Setting Standards (1.b.ii) through evidence set out in the annexes supporting Shared Standards. The evidence is extensive and demonstrates, inter alia, that:
• The Water Resource Management Plans (WRMPs), prepared by water companies, in the Shared Standards area demonstrate that a there are significant challenges in meeting predicted domestic and non-domestic growth in water demand whilst also meeting statutory environmental obligations (i.e. there are non-domestic water restrictions Anglian Water's area).
• Water efficiency is needed for protected sites and wider nature recovery. Of the 239 SSSIs in the Shared Standards area, 96 at time of writing, have water abstraction identified as an active pressure. Many have measures in place to address these pressures linked in many cases to the plan-led approach. The Shared Standards complement or support the delivery of those measures.
• At present it is feasible to achieve a total consumption of 85 l/p/d by taking a fittings-based approach using product types outlined in the Shared Standards Annex C.

Anglian Water would also seek to promote our environmental incentive scheme we provide for water to help manage water more efficiently in new developments and help safeguard water resources. By planning water efficiency from the start, developers can deliver cost-effective, resilient, and future-ready homes without adding unnecessary complexity to developments. The Environmental Incentive Scheme rewards developments that make sustainable design choices, benefiting both development projects and the environment. There are two tiers available – one for new build homes installed with fixtures and fittings to meet a usage requirement of 90 litres/person/day, and one for new build homes fitted with an operational rainwater harvesting or greywater recycling system. Direct reference to the environmental incentives in the Local Plan would highlight this opportunity with developers bringing forward residential development proposals.

Our Water Resources Management Plan 2025-2050 (WRMP24) sets out a strategy that focuses on demand management, two new raw water reservoirs, and utilising other sources of water. Please see our water resource zone (WRZ) summary for Norfolk which can assist with the baseline scoping evidence and evidence reports such as the Water Cycle Study.
We are also expanding our strategic water grid through our AMP8 programme of investments to strengthen our ability to respond to drought and future climate challenges, and ensuring we have a sustainable water supply for people and nature. Further details can be found on our website, which illustrates some of the proposed pipelines to be delivered in Norfolk:
https://www.anglianwater.co.uk/environment/investing-in-the-future-of-water/strategic-pipeline-alliance/keeping-taps-flowing-for-future-generations

Our current Drought Plan was published in April 2022 (Drought Plan 2022 or DP22) and these documents are available to view on our website. We have also been developing our next Drought Plan (DP27), and held a public consultation on our draft DP27 on 11 May 2026 to 17 July 2026. The Drought Plan sets out how we will prepare for, respond to, and recover from drought. This latest Plan (DP27) takes into account the updated climate change forecasts, our latest investments (such as our strategic pipeline and smart metering rollout) and strategies for managing water over the long term.

Flood Risk:
Anglian Water is a Risk Management Authority, as water and sewerage companies are responsible for managing the risks of flooding from water mains, surface water and foul or combined sewer systems. The Strategic Flood Risk Assessment should guide the spatial distribution of growth to those areas that have the lowest risk of flooding from all sources.

The following Anglian Water reports outline how we are proactively addressing a reduction in pollution incidents, flooding incidents, and spills from storm overflows.
Pollution Incident Reduction Plan 2026
Flood Incident Reduction Plan 2025
Storm Overflow Action Plan
We provide Surface Water Risk Management guidance and advice to developers. The Local Plan could helpfully signpost developers to engage with Anglian Water if development proposals seek to connect to the surface water sewer network - Surface Water Risk Management. Local Plan policies should ensure surface water flood risk is appropriately managed in all new development proposals and all development must demonstrate that surface water run-off is managed in accordance with the drainage hierarchy (see National standards for sustainable drainage systems Standard 1).
Under Ofwat’s Code for Adoption Agreements, surface water drainage assets can be presented to sewerage companies for adoption. Since 1 April 2020, this includes SuDS which are considered to be sewers. Anglian Water has published design and construction standards for SuDS which must be followed if developers apply to have their proposed SuDS scheme adopted by us.
https://www.anglianwater.co.uk/developing/drainage-services/sustainable-drainage-systems
https://www.anglianwater.co.uk/siteassets/developers/drainage-services/aws-suds-guide-sm.pdf
We would welcome policy measures to ensure that all new developments incorporate SuDS and no new connections are made to our foul or combined drainage networks (NDMP F8).

Nature recovery and biodiversity enhancement
Anglian Water supports locally specific policies that implement the Norfolk Local Nature Recovery Strategy and integrate water quality, flood resilience, low-flow improvements and habitat connectivity.
Anglian Water is supportive of a policy approach that helps to strengthen the measures and opportunities set out in the Local Nature Recovery Strategy (LNRS) for Norfolk. These align with our purpose and strategic priorities, helping to enable sustainable growth and resilience in an environmentally significant region. One of the best things we can do for the environment is leave more water in it, which is why we have had a long-standing strategy to reduce abstraction, leakage and increase sources of alternative supply. Furthermore, programmes such as the Water Industry National Environment Programme (WINEP) and Get River Positive have provided strong evidence for partnership-based approaches to improve the environment at both a catchment and landscape scale. Nature based solutions in urban and rural environments help to reduce flood risk, retain valuable water resources and improve water quality. Anglian Water’s WINEP programme is worth ~£2billion, one of the biggest environmental programmes in the sector. This investment is more than double that of AMP7 (2020-2025 period) delivering a range of environmental outcomes from the reduction of spills from storm overflows, improving the water quality of final effluent from our Water Recycling Centres, increasing river resilience during low flows and protecting/enhancing biodiversity, amongst many others.

Our Advanced WINEP (A-WINEP) investment aims to demonstrate an approach to maximise value by going even further for the environment through partnership working (including co-development and co-funding), focussing on the use of nature-based solutions, implementing solutions to water management challenges at scale, and improved multi-stakeholder governance. The A-WINEP has clear potential to contribute to some of the biodiversity priorities and strategic opportunities which relate to rural regeneration (nature-based solutions and land management) within the LNRS area.  

The A-WINEP region of interest extends to 11 river catchments that including those across Norfolk. Catchment Plans will be created for the initial 11 catchments within the A-WINEP rural regeneration programme, which will be developed over the full duration of the A-WINEP and will provide a holistic approach to catchment regeneration. Projects that seek A-WINEP match funding must address two primary outcomes:
• the reduction of nutrient pollution into rivers and 
• mitigating the impact of low flow. 

It is considered that our A-WINEP rural regeneration programme will help deliver the strategic aims identified in the LNRS – particularly around climate change, internationally important chalk streams, and water quality and resources.

We would wish to see policy measures in place to ensure that development proposals appropriately consider source protection zones (SPZs) and where necessary, further assessments made where development proposals could impact on water quality.

Any enhanced biodiversity net gain requirement should be consistent with national policy and applied proportionately (NPPF Policy N1, 2). Proposals for utility infrastructure, especially linear pipelines crossing multiple landownerships and operational sites where long-term onsite habitat management or future infrastructure expansion may limit the scope for onsite BNG delivery as operational sites might be unable to expand, or Anglian Water is not the landowner and therefore a 30-year habitat management cannot be guaranteed.

Green infrastructure
Green and blue infrastructure (G&BI), provides multi-functional benefits including in terms of improving water quality, incorporating sustainable drainage systems to reduce flood risk, and natural flood management measures (NPPF – Policy N1 d sates that plan-making policies should set out standards for green infrastructure provision). These are all promoted through the LNRS. Anglian Water prioritises a SuDS-first approach to managing surface water flood risk, in accordance with the drainage hierarchy (NDMP DP3, N3 and F8).

Anglian Water supports the proposed evidence programme which identifies the iterative stages for the Water Cycle Study, Strategic Flood Risk Assessment and Infrastructure Needs Study to enable infrastructure and environmental evidence to be prepared as the growth options for the GNLP 2045 are refined. Anglian Water will liaise with the GNLP authorities to provide data and advice to support these studies and the spatial distribution of growth. We will ensure that data sharing agreement is in place to enable these studies to proceed with the relevant datasets.

We agree that as most of the Norfolk LPAs are on similar timescales for local plan preparation, there are opportunities to pursue shared evidence through the Norfolk Strategic Planning Framework.

The site-assessment methodology should explicitly consider above- and below-ground assets, easements, operational land, planned investment, access requirements and any encroachment buffers needed to protect amenity and allow future infrastructure expansion.

Anglian Water broadly agrees with the proposed engagement approach, including the identification of the purpose, target audiences and methods at each statutory stage. The digital-first approach is appropriate, provided non-digital alternatives remain available.
For statutory infrastructure providers, engagement should not be limited to formal consultation periods. We would also support:
• stakeholder workshops – general/topic-based;
• direct engagement on evidence such as Water Cycle Study, SFRA, and IDP;
• sufficient notice of emerging growth trajectories so that implications can be assessed; and
• continued engagement between statutory stages as evidence changes.
Anglian Water is content to participate through online consultations, written submissions, virtual meetings and targeted workshops. Given the number of Norfolk planning authorities preparing plans under the new system, there may also be value in coordinated cross-boundary workshops on common matters such as water resources, nutrient neutrality, wastewater investment, flood risk, green infrastructure and water efficiency.

Anglian Water recommends that formal consultations end at 23:59 on the prescribed day to align with other Government and LPA deadline requirements, and to allow flexibility for all respondents to the consultations.
Is it possible to upgrade this platform to provide an AI summary of responses over 100 words? This makes it time-consuming for respondents to submit, particularly stakeholders responding to multiple plans, and therefore might result in submissions via email.

Anglian Water welcomes the opportunity to comment on the Greater Norwich Local Plan 2045 Scoping Consultation. We support an evidence-led growth strategy which aligns development with water resources, wastewater infrastructure, environmental capacity and climate resilience.

We would welcome continued engagement with the Greater Norwich authorities on the Water Cycle Study or Integrated Water Management Study, Strategic Flood Risk Assessment, Habitat Regulations Assessment, Infrastructure Delivery Plan, site-assessment methodology and the development of locally specific policies. Early collaboration will help identify sustainable growth locations, appropriate infrastructure pathways and any necessary phasing, while protecting existing customers, water resources and the environment.