MP4. Agricultural or potable water reservoirs

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Object

Preferred Options consultation document

Representation ID: 98333

Received: 30/10/2019

Respondent: Anglian Water Services Ltd

Representation:

The need for any additional potable water reservoirs in the Anglian Water company area would be identified through our Water Resource Management Plan (WRMP) which identifies how we will manage the supply/demand balance to continue to supply water our existing and new customers.

Anglian Water's Revised Draft WRMP identifies a number of potential (water) supply side options include winter storage reservoirs in South Lincolnshire and South Fenland.
Currently Anglian Water is undertaking some initial technical work on these and the other options identified in the WRMP (please see page 88 for further details). However it is important to emphasise that the reservoirs are currently options only. No decisions have been by Anglian Water about whether these options will be included in the next WRMP to be published in 2024.

Additional criteria has been added to Policy MP4 following the previous consultation to limit the scale of reservoirs to the minimum possible and to ensure the early delivery of water resources.

The timing of any required reservoirs for potable water for public supply would be determined through the WRMP process which is approved by Defra following consultation with the Environment Agency and other interested parties. It is therefore unclear whether the appropriateness of any proposed timing should be considered as part of the planning application process.

Similarly what is the intended purpose of limiting the scale of any reservoir and how would this be considered as part of any application.

It is currently unclear whether the criteria are currently effective as currently drafted and we would welcome clarification of what is intended. As there is no further explanation of how applicants could demonstrate that the criteria has been met it suggested that it should be removed.

Full text:


NOTE: Additions in BOLD CAPITAL LETTERS, removals in [lower case example]

Thank you for the opportunity to comment on the Norfolk Minerals and Waste Local Plan Review. The following comments are submitted on behalf of Anglian Water.
I would be grateful if you could confirm that you have received this response.

Policy MW4: Climate change mitigation and adaption
We note that Policy MW4 refers to both the use of Sustainable Drainage System, water harvesting and waste water recycling which is generally supported.
Anglian Water has some detailed comments on the wording of this requirement to ensure the policy is effective. Given the nature of mineral extraction and waste management proposals vary significantly there is a need to ensure that policy MW4 is flexible in this regard.

Surfacewater or stormwater harvesting refers to where rainfall has reached the ground and the system can collect surface water run off including permeable or impermeable surfaces. It is not made clear whether this intended to refer to stormwater harvesting or rainwater harvesting from roofs.

Waste water recycling or grey water recycling would be appropriate for minerals and waste management proposals that drain domestic foul flows to the public sewerage network. Where this is not the case grey water recycling would not be practicable.
It is therefore proposed that Policy MW4 be amended as follows:
'd) demonstrate the use of sustainable drainage systems, RAINWATER HARVESTING, STORMWATER harvesting INCLUDING from impermeable surfaces WHEREVER FEASIBLE and layouts that accommodate waste water recycling WHERE A CONNECTION TO THE PUBLIC SEWERAGE NETWORK IS REQUIRED;'

Policy WP2: Spatial Strategy for waste management facilities
Anglian Water is generally supportive of the final paragraph of WP2 as drafted. We note that changes have made to the policy to make refer to a distinction between water recycling centres and sewage pumping stations as set out in earlier representations which is welcomed.

We would ask that Policy WP2 is positively phrased in relation to water recycling centres for consistency with the the National Planning Policy Framework.
It is therefore proposed that Policy WP2 be amended as follows:

'Water recycling centres can normally only be located on or adjacent to watercourses, so they [will normally only be] ARE acceptable in such locations.'
Policy WP3: Land potentially suitable for waste management facilities
Reference is made to waste management facilities on water recycling centres being limited to composting and anaerobic digestion.

Anglian Water as sewerage undertaker is concerned that this is not justified in that there may be other waste management uses which would be suitable at water recycling centres dependant upon both scale and location.

It is therefore suggested that the above wording is removed or amended to allow for other waste management uses.

It is therefore proposed that criterion f of Policy WP3 be amended as follows:
'f) waste recycling centres [(composting and anaerobic digestion only);']

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.
We note that some changes have been made in response to our previous comments although not all of the suggested changes have been included. The final paragraph also seems to suggest that the applicant would be required to demonstrate the need for the proposed location. As there is no further explanation of how this would be demonstrated it suggested that it should be removed.

It is therefore proposed that the first paragraph of Policy WP14 be amended as follows:

'New or extended Water Recycling Centres or improvements to existing sites AND SUPPORTING INFRASTRUCTURE (INCLUDING RENEWABLE ENERGY) will [only] be acceptable 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.
[The applicant will be required to demonstrate that the proposal can be located without giving rise to unacceptable environmental impacts.']
Para 15.3 - reference is made to Anglian Water's Business Planning process which is produced once every 5 years and approved by our economic regulator Ofwat. As drafted it appears to suggest that there is no information currently available about planned investment at Whitlingham Water Recycling Centre over the plan period.
We have submitted our business plan for AMP 7 (2020 to 2025) to Ofwat and expect to receive final determination in December 2019. However Anglian Water has committed investment at Whitlingham Water Recycling Centre of £17million to accommodate further growth to 2031.

The investment at Whitlingham Water Recycling Centre is not reliant upon the determination of the business plan for AMP 7 as it forms part of our approved business plan for AMP 6 (2015 to 2020).

We are aware that the Greater Norwich Local Plan is currently being reviewed. The expectation is that Anglian Water would review the need for additional investment at Whitlingham Water Recycling Centre through the preparation of the Drainage and Wastewater Management Plan (DWMP) by 2022. Further details of the scope of DWMPs is available to view at the following address:

https://www.water.org.uk/wp-content/uploads/2019/09/Working-together-to-improve-drainage-and-environmental-water-quality-an-overview-of-Drainage-and-Wastewater-Management-Plans.pdf

Para 15.4 - reference is made to extending the membership of liaison group for Whitlingham Water Recycling Centre and changing its purpose. This group focussed on operational issues only and was not intended to consider wider issues. We would welcome further discussions with Norfolk County Council about the issues identified and the appropriate forum(s) for the issues identified to be discussed with Anglian Water.

Para 15.5 - reference is made to the need for Anglian Water to develop a long term masterplan/implementation strategy for Whitlingham Water Recycling Centre with the Greater Norwich Growth Board and the Environment Agency. As drafted it is suggested that there is a need for specific strategy for this site in addition to any plans produced by Anglian Water.

As set out in our response to the previous consultation we have recognised the need for a long term strategy for water recycling centres and within the foul sewerage network to accommodate further growth as set out in our Water Recycling Long Term Plan. We also be producing a Drainage and Wastewater Management Plan which will consider the need for further investment at our existing water recycling centres which is expected to be developed with the Norfolk authorities, Broads Authority and the Environment Agency.

We would therefore suggest that the supporting text of Policy WP15 of the Local Plan be amended to make this clear.

Policy WP15: Whitlingham Water Recycling Centre
Reference is made to the need for Anglian Water to develop a long term masterplan/implementation strategy for Whitlingham Water Recycling Centre with the Greater Norwich Growth Board and the Environment Agency. As drafted it is suggested that there is a need for specific strategy for this site in addition to any long term plans produced by Anglian Water.

As set out in our response to the previous consultation we have recognised the need for a long term strategy for water recycling centres and within the foul sewerage network to accommodate further growth as set out in our Water Recycling Long Term Plan.

We also anticipate reviewing the need for additional investment at Whitlingham Water Recycling Centre through the preparation of the Drainage and Wastewater Management Plan which is expected to be developed with the Norfolk authorities, Broads Authority and the Environment Agency as such we would suggest that a separate masterplan or similar is not required.

Anglian Water is open to discussion about the need and format for on-going liaison with the Norfolk Authorities, the Environment Agency, other interested parties and local residents. However we don't consider it is necessary to specify the purpose and membership of a liaison group in the wording of a Local Plan policy.

Policy WP15 as drafted includes specific criteria which apply to all development proposals at Whitlingham WRC. As set out in our previous representations 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. However the policy doesn't appear to have been amended to address Anglian Water's earlier comments.

Therefore we would suggest that the wording of policy WLP15 should be reviewed to consider in what circumstances it would be applied.

It is therefore proposed that Policy WP15 of the local plan is amended as follows:
Any proposals for the improvement of the WWRC [must be accompanied by ]should be consistent with a longer-term strategy [masterplan ] for the WW[T]RC WHICH FORMS PART OF ANGLIAN WATER'S DRAINAGE AND WASTEWATER MANAGEMENT PLAN, produced in collaboration with the constituent authorities of the Greater Norwich Growth Board and the Environment Agency.

The County Council will work closely with Anglian Water, the Environment Agency, South Norfolk Council and the Broads Authority to ensure that development proposals at Whitlingham WRC WHERE RELEVANT TO THE SUBMITTED APPLICATION will:

a) Minimise the effect on the amenity of local residents, with particular emphasis on noise and odour;
b) Route all HGV movements to and from the site via the C202 Kirby Road and the A146 Loddon Road, with the routing of HGV movements to be controlled through planning conditions or Section 106 Legal Agreement as appropriate;
c) Not affect adversely the landscape setting of the Broads by insensitively locating and/or designing equipment or buildings on the site; and
d) In line with the requirements of the NPPF and National Planning Practice Guidance, choose preferentially locations within Flood Zone 1, and where locations in Flood Zone 2 or 3 are proposed, adequate measures to control pollution and manage sewage during flooding events are put in place, to be controlled by either a Section 106 Legal Agreement or planning condition(s) as appropriate.

[The following parties should form part of the Local Liaison Group: Kirby Bedon Parish Council, Trowse Parish Council, Postwick Parish Council, Thorpe St Andrew Council, local residents, Anglian Water, the Environment Agency, Norfolk County Council, South Norfolk Council and the Broads Authority. The Liaison Group should consider requests from other organisations to join the group. The Local Liaison Group should continue to meet regularly to discuss operational issues, and planned site improvements.']

Policy WP17: Safeguarding Waste Management Facilities
Anglian Water as a sewerage company is generally supportive of the final paragraph of WP17 as drafted. We note that changes have made to the policy to allow for a change of circumstances as set out in earlier representations which is welcomed.
Reference is made to a distance of 400m being used for any proposals in the vicinity of a Water Recycling Centre managed by Anglian Water. Anglian Water's existing Asset Encroachment Policy is currently being reviewed as such we would suggest the policy be amended to provide flexibility to allow for any changes to this distance for individual WRCs.
In relation to sewage pumping stations we would expect to be consulted on proposals for occupied land and buildings within 15m of an existing pumping station consistent with the requirements of Sewers for Adoption.
It is therefore proposed that Policy WP17 of the Local Plan is amended as follows:
'The County Council will safeguard existing and permitted waste management facilities, within the following categories:
* Waste management facilities with a permitted input of over 20,000 tonnes per annum;
* Key water recycling centres (listed in Appendix 8);
* Waste water pumping stations;
Consultation areas are delineated on the Policies Map and extend to 250 metres from each safeguarded waste management facility, and 400 metres from each safeguarded water recycling centre (OR A DISTANCE SPECIFIED BY ANGLIAN WATER IN ANY SUCCESSOR DOCUMENT). The Waste Planning Authority should be consulted on all development proposals within these consultation areas, except for the excluded development types set out in Appendix 4.
Development proposals within the defined consultation areas around safeguarded facilities should demonstrate that they would not prevent or prejudice the use of those facilities. The County Council will oppose development proposals which would prevent or prejudice the use of safeguarded facilities for those purposes unless suitable alternative provision is made, or the applicant demonstrates that those facilities no longer meet the needs of the waste management industry or ANGLIAN WATER AS THE relevant sewerage company.
'In addition, any development which includes OCCUPIED LAND OR BUILDINGS proposed within 15 [50] metres of a pumping station (as identified through the planning application) will be subject to consultation with the relevant sewerage company by the planning authority responsible for determining the application. '

Policy MP4 - Agricultural or potable reservoirs
The need for any additional potable water reservoirs in the Anglian Water company area would be identified through our Water Resource Management Plan (WRMP) which identifies how we will manage the supply/demand balance to continue to supply water our existing and new customers.
Anglian Water's Revised Draft WRMP identifies a number of potential (water) supply side options include winter storage reservoirs in South Lincolnshire and South Fenland.
Currently Anglian Water is undertaking some initial technical work on these and the other options identified in the WRMP (please see page 88 for further details). However it is important to emphasise that the reservoirs are currently options only. No decisions have been by Anglian Water about whether these options will be included in the next WRMP to be published in 2024.
Additional criteria has been added to Policy MP4 following the previous consultation to limit the scale of reservoirs to the minimum possible and to ensure the early delivery of water resources.
The timing of any required reservoirs for potable water for public supply would be determined through the WRMP process which is approved by Defra following consultation with the Environnment Agency and other interested parties. It is therefore unclear whether the appropriateness of any proposed timing should be considered as part of the planning application process.
Similarly what is the intended purpose of limiting the scale of any reservoir and how would this be considered as part of any application.
It is currently unclear whether the criteria are currently effective as currently drafted and we would welcome clarification of what is intended. As there is no further explanation of how applicants could demonstrate that the criteria has been met it suggested that it should be removed.

SIL 02 - land at Shouldham and Marham (silica sand)
We note that the above site is identified as a preferred area for an allocation for silica extraction rather than a site specific allocation or an area of search.
This site is located over a principal aquifer (bedrock) and partially over a Secondary A aquifer (superficial deposits). The eastern part of the site is within groundwater Source Protection Zone 1, however, this has been excluded from the proposed extraction area. The rest of the site is not within a groundwater SPZ. A planning application for mineral extraction at this site would need to include a Hydrogeological Risk Assessment to identify any potential impacts to groundwater and appropriate mitigation measures.
The text for this site includes reference to this requirement as requested by Anglian Water in our previous comments on the Local Plan which is welcomed. However there is no specific policy for this site or reference to the requirement for a Hydrogeological Risk Assessment to be submitted with any planning application.
To ensure that this is a requirement for any proposals for mineral extraction on this site we would ask that reference to this requirement is made in a policy or policies as appropriate rather than the supporting text as proposed.

Policy MP13: Areas of search for silica sand extraction
Anglian Water supports the inclusion of a requirement for a Hydrogeological Risk Assessment to be provided for applicants of sites within the identified areas of search for silica sand.

Appendix 4: Development excluding from safeguarding provisions
We recognise the need for taking a proportionate approach to development proposals which could affect the continued operation of existing water management facilities including water recycling centres.
However Anglian Water wish to be consulted on all residential development proposals which could be affected by the normal operation of a WRC.

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

Comment

Preferred Options consultation document

Representation ID: 98967

Received: 15/10/2019

Respondent: Broads Authority

Representation:

MP4.1 and MP4 - how about if the reservoir is not associated with mineral abstraction?

Full text:

* 1.5 - one specific site[s] for carstone extraction
* 1.14 - tpa - presume that is tonnes per annum - not used consistently in this para
* Page 12 - SA section - bullet point list does not mention landscape impact or biodiversity
* 5.16 The area known as the [Breaks] Brecks
* Where is MW1? The first policy is MW2.
* MW2 - The first part is written in quite a different way to other policies I have read; rather than saying that impacts of development will be minimised on the criteria, or schemes will address the criteria, you ask for information only. I am not sure how strong this approach is. b) what about the quantity of surface water (as in what to do with it in relation to flooding) and the quality of water bodies? E) what agriculture land class do you consider this to be - Grade 1 and 2 perhaps - might need to say that. What about if the soil that is to be excavated or disturbed is peat soils? Peat soils have many special qualities, such as are a carbon sink but a carbon source if allowed to dry out. We recommend that you consider protecting Peat Soils - you can look at our Peat Soils policy for ideas. i) what are 'outdoor recreation facilities' and do you need to include Local Green Space as well as Open Space?
* 8.12 - request there is some text, perhaps as a footnote, that refers to the identified dark skies of the Broads and refers to our maps and policy.
* 8.16 says 'Directing lighting downwards and away from properties' but taking this literally, this contradicts - implying angling the light away from properties which could cause light pollution. I think you are saying design any lighting so it points downwards and ensure that there is no light trespass for example into neighbouring properties. You might want to consider that wording and you might want to look at our policy on light pollution. The key point is - do you really need lighting, if so why? Keep it to a minimum, use it when needed and point it down and have it fully shielded - I suggest you get those points across strongly in the policy.
* 8.24 first bullet point - weave in wording that refers to the setting of the landscapes.
* 8.31 and section 12 - I see you refer to soil grades 1, 2 and 3a. As a bit of advice from our experience, do you know where 3a is? There is limited mapping relating to 3a. You might want to consider removing this or just saying '3'. Happy to chat this through. Should the soil grade be mentioned in the policy? Note what is said on page 73, I - that 3a and 3b are not mapped.
* 8.32, 12.2 - temporary yes, but for a number of years. Suggest that text is clarified. See above regarding if the soil is peat soils and its care.
* 8.35 - is it worth asking applicants to state how they have considered water and rail and road and thoroughly justify their chosen mode, rather than just encourage it?
* MW3, last bullet point - is that a travel plan? MW4 refers to travel plans.
* MW4 - is it better to just say 'greenhouse gas emissions'? Does using the term 'endeavour' reduce the strength of criterion c? d) just demonstrate or implement too?
* 12.4 says 'Given their nature, most waste management facilities will tend to be suitably located on previously developed land and industrial locations and it is not expected that there will be a great need to locate such uses on agricultural land' - not sure what this is saying - they tend to be located there or are suitable to be located there?
* Map 3 - see above comments - where are areas of 3a?
* Section 12 - no mention of peat soils and their qualities - see above.
* Page 41 onwards and then 64 onwards - formatting - should this have a section number - perhaps section 13? The bullet points are numbered differently to elsewhere in the Plan - WO rather than, say, 13.2 etc.
* WP4 - a) when compared to another option that takes longer?
* W7.1 - do you mean 2018?
* WP13 - so a, b, c are 'or' and d, e, f are 'and'. It might be easier to separate them out and say something like 'in all cases d, e, f will apply'.
* WP15 - first para seems reasoned justification rather than policy text. Suggest the Broad Authority be involved in the organisations listed in para 3 - the organisations in para 4 seem to be the ones that need to be involved in the Masterplan.
* WP17 and MP11 - on adoption, presume we will be sent these GIS layers to upload to our system?
* Page 71, and MP2 - that NPPF paragraph applies to the Broads too. We have a Major Development policy. Why is the AONB excluded and the Broads not? Or is it?
* Page 73, g - why not the undesignated heritage assets?
* MP2.14 - 'Developers wanting to [extraction] extract mineral from specific sites or land within an area of search allocated in the Minerals and Waste Local Plan Review will still need to apply for and be granted planning permission before mineral extraction can take place'.
* MP2 - why the 3mile/5 mile rule for minerals?
* MP4.1 and MP4 - how about if the reservoir is not associated with mineral abstraction?
* Page 76 - what is shown on this map? There is no key. If it is core river valleys, why are the rivers over in the Broads not blue?
* MP6 might make sense but the first part says acceptable, unacceptable and acceptable. A check might be needed.
* MP8.3 'The need for annual reports after the initial five-year period [for] will be assessed on a case by case basis'.
* M65.5 - starts off saying 'The site is not located within...'. Being within is one issue, but affecting the setting of is another. So such assessments should state whether the site is near to those designations. This should therefore correctly read that the site is near to the Broads.
* Page 181 onwards - Min 38 - Waveney Forest, Fritton - support not allocating this site.
* Min 65, Stanninghall Quarry - extension to existing minerals site. No landscape visual or character concerns with regards to the Broads itself.
* Min 25, we would definitely want to be consulted on any forthcoming planning applications on this site, particularly concerning landscape scheme and restoration as the landscape character areas in this locality are well defined and susceptible to change.
* Min 211, Restoration as wet grassland for biodiversity needs to be balanced with long-term effects on local landscape character. The local character and experience of the landscape varies between the north and south of the site and restoration should reflect this.
* Generally, an LVIA assesses the effects of a development (the impact) on the landscape as a resource and the effects on visual receptors. The assessment will cover both the site itself and a wider study area determined by desk study and ground-truthing. LVIA's should be carried out to a set standard (Guidelines for landscape and visual impact assessment, 3d edition - which I believe is part of the NCC validation checklist) so by definition will be required to include the site and any surrounding area that could be affected by the development; Existing: "Submission of a Landscape and Visual Impact Assessment which will identify any potential impacts to the wider landscape and suggest appropriate mitigation measures ..." Proposed: "Submission of a Landscape and Visual Impact Assessment which will identify any potential effects and suggest appropriate mitigation measures ..." This text is used across a number of the policies.

SA Part A Scoping
Page 31 needs a very big update.
* Core Strategy, DM and Sites not in place any more.
* Local Plan adopted May 2019.
* Flood Risk SPD - most recent is 2017
* Broads Plan is 2017
Seems relevant to refer to our dark skies data and policy

SA - Part B
4.5 - did you consider a zone from the Broads?


Please note: The Broads Authority has adopted a new Local Plan which can be found here. The policies in the Core Strategy, Development Management and Site Specific documents are all superseded and not in place anymore.