Policy WP15: Whitlingham Water Recycling Centre
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99229
Received: 14/12/2022
Respondent: Historic England
We welcome the reference to Crown Point RPG in the policy.
Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99281
Received: 14/12/2022
Respondent: Anglian Water
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Local Plan is unsound because Policy WP15 is not positively prepared in terms of achieving sustainable development or justified given reasonable alternatives.
We support the amendments to the policy because of our previous consultation submission to the Preferred Options consultation in 2019. However, there remains an outstanding area of concern that we wish to raise, as a result of our comments on the supporting text above, regarding our current and emerging plans and strategies that provide further detail regarding future investments at Whitlingham WRC.
PROPOSED POLICY MODIFICATION: Our draft DWMP consultation was undertaken with a wide range of stakeholders including local authorities and The Environment Agency. The policy does not need to reference the requirement for a longer-term masterplan as this aspect is fulfilled by the DWMP, which Councils are consulted on, and future AMP (Asset Management Plan) periods for investments in capital programmes. Therefore it is proposed that Policy WP15 of the local plan is amended.
We acknowledge that The Broads SAC (Special Area of Conservation) and the Crown Point Registered Park and Garden are designated wildlife and heritage sites in proximity to Whitlingham WRC and these are identified in the newly introduced criteria d. and e. of the policy. We would question why these criteria are specifically required when natural and historic environment criteria are already wholly addressed through Policy MW1, together with other natural and historic environment designations and assets. We consider that Policy MW1 provides a comprehensive approach to the relevant development management criteria that should underpin development proposals that require planning permission at our WRCs, including Whitlingham WRC.
PROPOSED POLICY MODIFICATION: Our draft DWMP consultation was undertaken with a wide range of stakeholders including local authorities and The Environment Agency. The policy does not need to reference the requirement for a longer-term masterplan as this aspect is fulfilled by the DWMP, which Councils are consulted on, and future AMP (Asset Management Plan) periods for investments in capital programmes. Therefore, it is proposed that Policy WP15 of the local plan is amended as follows:
"Any proposals for the improvement of the WRC must [delete: be accompanied by and] be consistent with a longer-term [delete: 'masterplan'] [insert: 'strategy'] for the WRC [insert: 'which forms part of Anglian Water's Drainage and Wastewater Management Plan, or is required to:'] [delete: produced in collaboration with the constituent authorities of the Greater Norwich Growth Board, the Broads Authority and the Environment Agency'].
[insert: 'a) comply with new legislation; and/or
b) accommodate growth within, or connecting to, the Whitlingham water recycling catchment.']
We would question why criteria d. and e. are specifically required when natural and historic environment criteria are already wholly addressed through Policy MW1, together with other natural and historic environment designations and assets.
Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99456
Received: 19/12/2022
Respondent: Breckland District Council
Consider whether the policy should refer to water quality improvements required at this site?