Comment

Initial Consultation document

Representation ID: 92489

Received: 13/08/2018

Respondent: Anglian Water Services Ltd

Representation Summary:

Anglian Water is largely supportive of Policy WP14 as drafted but has some comments particularly in relation to making the policy more positive in enabling the continued operation and development of existing water recycling centres) to enable Anglian Water to fulfil our statutory obligations under the Water Industry Act 1991.

It is therefore proposed that the first paragraph of Policy WLP14 be amended as follows (additional text in BOLD):
'New or extended Water Recycling Centres OR IMPROVEMENTS TO EXISTING SITES AND SUPPORTING INFRASTRUCTURE (INCLUDING RENEWABLE ENERGY) WILL be acceptable IN PRINCIPAL where such proposals aim to:
a) treat a greater quantity of wastewater; and/or
b) improve the quality of discharged water; and/or
c) reduce the environmental impact of operation.'

Full text:

Thank you for the opportunity to comment on the Norfolk Minerals and Waste Local Plan Initial consultation. The following comments are submitted on behalf of Anglian Water.

I would be grateful if you could confirm that you have received the following response.

Part 1: Initial consultation policies

Question 11: Policy WP2 'spatial strategy for waste management facilities'

Anglian Water is generally supportive of the final paragraph of WP2 as drafted. However a distinction needs to be made between Water Recycling Centres which discharge to a watercourses and pumping stations which can convey foul flows between sewers rather than discharge to a watercourse as suggested.

Question 12: Policy WP3 'land uses potentially suitable for waste management facilities'

Anglian Water as a sewerage company is generally supportive of the final paragraph of WP3 as drafted. However evidence does not appear to have been provided for the proposal to limit the co-location of waste management uses to composting and anaerobic digestion on water recycling centre sites.

Therefore it is suggested that Policy WP3 should be amended as follows:

'f) water recycling centres; '

Question 23: Policy WP14 'Water Recycling Centres'

Anglian Water is largely supportive of Policy WP14 as drafted but has some comments particularly in relation to making the policy more positive in enabling the continued operation and development of existing water recycling centres) to enable Anglian Water to fulfil our statutory obligations under the Water Industry Act 1991.

It is therefore proposed that the first paragraph of Policy WLP14 be amended as follows:
'New or extended Water Recycling Centres or improvements to existing sites and supporting infrastructure (including renewable energy) will be acceptable in principle where such proposals aim to:
a) treat a greater quantity of wastewater; and/or
b) improve the quality of discharged water; and/or
c) reduce the environmental impact of operation.'

Question 24: Policy WP15 'Whitlingham Water Recycling Centre'

Policy WLP15 appears to be largely a continuation of Policy CS12 of the adopted Norfolk Minerals and Waste Core Strategy. We recognise the importance of Whitlingham Water Recycling Centre as a strategic asset and the need to work with the Greater Norwich authorities to develop an effective to shape operational enhancements from future technologies and planned investment to accommodate further growth.

Reference is made to Anglian Water developing a long term vision for Whitlingham Water Recycling Centre with the Greater Norwich Growth Board and the EA.

Anglian Water has recognised the need to take a long term view in relation to future investment at WRCs and within the foul sewerage network similar to the Water Resource Management Plan. The Minerals and Waste Local Plan Review should have regard to the WRLTP in relation to the planned investment within Norfolk County as part of next business and future business plans.

We are currently in the process of finalising a Water Recycling Long Term Plan (WRLTP) which will set out a long term strategy to identify the need for further investment by Anglian Water at existing Water Recycling Centres or within the foul sewerage catchments to accommodate the anticipated scale and timing of growth in the company area. This document once finalised will be used to inform future business plans including the plan for 2020 to 2025 which is expected to be approved by our economic regulator Ofwat in December 2019.

Policy WLP15 as drafted includes specific criteria which apply to all development proposals at Whitlingham WRC. It is unclear whether this would apply to all development proposals on this site - for example if the proposal did not generate any additional traffic movements. Therefore we would suggest that the wording of policy WLP15 should be reviewed to consider in what circumstances it would be applied and how it relates to Policy WP15 given that the development plan is intended to be read as whole. As part of which consideration should be given to whether there is need for a separate policy as suggested.

Question 26: Policy WP17 'Safeguarding waste management facilities'

Anglian Water as a sewerage company is generally supportive of the final paragraph of W11 as drafted. However the policy should allow for a change of circumstance for example if the relevant sewerage company identifies that existing water recycling asset is no longer required for operational reasons e.g. directing foul flows elsewhere within the public sewerage network.

Also for clarity the policy should refer to 'sewerage company' as opposed to wastewater management company as drafted.

Part 2 - Proposed Mineral extraction sites

It is noted that a number of Anglian Water assets are located within the site boundary for a number of sites identified in Part 2 of the Plan. Therefore we would ask that the policy wording for these sites exclude any existing assets from the proposed working area for mineral extraction to ensure that we can continue to operate and maintain these assets for our customers.

Should you have any queries relating to this response please let me know.