Minerals and Waste Local Plan: Pre-Submission Publication

Object

Representation ID: 99280

Received: 14/12/2022

Respondent: Anglian Water

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

As stated above [regarding paragraphs W15.2 - W15.3] and in previous consultation responses, we have clearly recognised the need for a long-term strategy for our water recycling centres and the foul sewerage network to accommodate further growth as set out in our Water Recycling Long Term Plan. The emerging Drainage and Wastewater Management Plan (DWMP) will consider the need for further investment at our existing water recycling centres which has been developed in consultation with the Norfolk authorities, The Broads Authority, and the Environment Agency. We would therefore suggest that the supporting text in this paragraph is amended to make this clear and ensure that reference to a masterplan is removed. It is not possible to produce a masterplan for the site as there are so many factors that can change overtime, which impact on our investments and capital programmes - including innovative technology, changes to emerging growth patterns, and changing legislative requirements. These changes include the proposed measures in the Levelling Up and Regeneration Bill to address nutrient issues. As an environmentally regulated utility, all works Anglian Water undertakes are necessary and have a clear purpose and wider environmental benefit. We regularly update our plans, engaging with our regulators, stakeholders and working in partnership with other stakeholders to provide positive environmental outcomes. The recent nutrient neutrality issue in Norfolk is one such issue that will have implications for future investments at certain WRCs within the River Wensum and The Broads catchments. Therefore, the requirement for a masterplan would put the delivery of strategic investment at Whitlingham WRC at risk.

Object

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.

Support

Representation ID: 99282

Received: 14/12/2022

Respondent: Anglian Water

We welcome the amendments to this policy following our representation on the Preferred Options consultation, which recognise the consultation areas extending from our WRCs and pumping stations.

Object

Representation ID: 99283

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 it is not justified given reasonable alternatives.

Whilst we welcome the introduction of the policy and its approach, we would welcome modifications to the policy and supporting text as follows":
We note that the Preferred Option M&WLP policy SIL 02 - land at Shouldham and Marham (silica sand) has been removed from the Publication M&WLP and replaced with new strategic policy MPSS1. We support the inclusion of criterion (f) to require an acceptable Hydrological Impact Assessment to identify any potential impacts to groundwater and appropriate mitigation measures.
Furthermore, we welcome inclusion of criterion (i) in the policy regarding sufficient stand-off distances around any water main that crosses the site or diversion of the water main at the developers' cost and to the satisfaction of Anglian Water. We recommend that the supporting text explains that the developer will need to confirm the stand-off distances with Anglian Water in advance of submitting their application.

Comment

Representation ID: 99284

Received: 14/12/2022

Respondent: Anglian Water

We welcome reference to Anglian Water's Water Resource Management Plan in the supporting text to provide context to Policy MP4.
Water Resource Management Plans play a crucial role in securing the public water supply for the region. The plan identifies the investment required to secure public water supply for the region whilst protecting and enhancing the environment. This is then projected into water company business plans. Every five years we develop our Water Resources Management Plan (WRMP) which sets out how we will manage the water supplies in our region to meet current and future needs over a minimum of 25 years. Our current Plan, published in 2019, covers the period from 2020-2045. We are now developing our next Plan (WRMP24) for the period 2025 - 2050.
The proposed strategic reservoir options in South Lincolnshire and The Fens are nationally strategic infrastructure and have been identified as strategic supply side options for addressing future water demand in the Anglian Water region due to population growth, climate change impacts and protecting the environment.
As nationally strategic infrastructure projects (NSIPs), these will be submitted as Development Consent Order applications to the Planning Inspectorate. An Examining Authority appointed by the Secretary of State and supported by the Planning Inspectorate examines the application and will make a recommendation to the relevant Secretary of State, who will make the decision on whether to grant or to refuse development consent. In such cases the Local Authority will not be the decision-maker but will provide a statutory local perspective throughout the process and be responsible for discharging the requirements associated with an NSIP in their area if development consent is granted.

Object

Representation ID: 99285

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 WP14 is not positively prepared in terms of achieving sustainable development or justified given reasonable alternatives.

Paragraphs W15.2 and 15.3: We are disappointed that these paragraphs infer that there is no information relating to planned improvements at Whitlingham WRC, even though information was provided in our submission to the Preferred Options consultation. Through our PR19 Business Plan we identified investment to extend our plant at Whitlingham to cater for growth and increased capacity to cater for the additional sludges from our water recycling centres as a result of higher environmental quality regulations. This will provide sufficient capacity to deal with the impacts of regional growth and for increased sludge loads received from other WRCs affected by the WINEP (Water Industry National Environment Programme) phosphate reduction programmes as they are delivered through AMP7. This investment strategy is based on a longer-term plan and the knowledge that further staged investment will be needed in AMP8 and AMP9 to keep ahead of the growth projections across the Anglian region and to respond to changes in environmental legislation.

Our draft Drainage and Wastewater Management Plan (DWMP) was published for consultation earlier in the summer and we are now reviewing the responses with a view to publish the final version in 2023. The DWMP will support the development of our Long- Term Delivery Strategy (LTDS) and our business plan for the 2024 Price Review (PR24).

The draft DWMP identifies Whitlingham WRC as a catchment where there is already partnership working. The medium-term strategy for the Whitlingham water recycling catchment is attenuation with a longer-term strategy to 2050 of surface water removal, a new permit, new process streams, and infiltration removal.

We strongly suggest that the text is revised to ensure that it accurately signposts the relevant plans and strategies prepared by Anglian Water that inform our investments for Whitlingham WRC, so that the Local Plan is referencing the correct information and decision­ makers can access the this information through the lifespan of the plan, as our own plans are updated every 5 years to take account of changes to growth projections, regulatory and legislative changes, and environmental implications. This ensures that we can plan effectively and invest where it is needed.

Comment

Representation ID: 99526

Received: 14/12/2022

Respondent: Anglian Water

It would be helpful if the supporting text explained that anaerobic digestion (AD) produces biogas (a mixture of around 60% methane and 40% carbon dioxide) and digestate, and that biogas can be burned directly in a gas boiler to produce heat or burnt in a combined heat and power (CHP) unit to produce heat and electricity.

Alternatively, the biogas can be cleaned to remove the carbon dioxide and other substances, to produce biomethane, which can be injected into the national gas grid to be used in the same way as natural gas or used as a vehicle fuel. This would demonstrate the options available from AD and replace the text in paragraph W9.1 that states methane gas drives a diesel generator.