Regulation 19 - Proposed Draft Local Plan Submission

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Regulation 19 - Proposed Draft Local Plan Submission

4.1

Representation ID: 13975

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

With reference to the adequate provision of ‘necessary infrastructure’ AWS has previously advised that with the exception of trade effluent from new or expanded businesses, the funding for new water and water recycling network and treatment capacity comes from our 5-year business plans agreed with EA and Ofwat. Developer contributions are not therefore a source of funding for delivery. Separate to developer charging through section 106, AWS has a general strategic charge for network capacity which covers a small proportion of some of the long-term strategic investment needed in wastewater network capacity.

Full text:

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Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

Policy DS01 Development Strategy: Delivering Homes

Representation ID: 13976

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

AWS supports the housing requirement figures, considering past growth rates and the spatial distribution of growth. As set out in representations document [see attachment] some of the allocations may not be immediately capable of connecting to the sewerage network without increasing the risk of pollution and so would either need to be managed through pre-occupation conditions or phased for dates after 2030, so that the investment can be secured in AWS future business plans.

Full text:

See attachment for representations.

Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

4.8

Representation ID: 13977

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

With regard to Neighbourhood Plans and Windfall sites, AWS would not support the growth of Other Villages/ Hamlets served by WRC with Descriptive Permits. These locations would only serve a relatively low number of homes and could disproportionately increase the risk of pollution in the receiving watercourse. AWS supports this position as there are significant carbon economies of scale if growth is at scale of a Sustainable Urban Extension serving more people than could be accommodated in small village expansion.

Full text:

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Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

4.10

Representation ID: 13978

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

Table 1 and 2. AWS agrees that a hierarchy of settlements (Table 1) enables the Plan to focus development on the more sustainable locations. Increasingly development will towards the end of the Plan period need to deliver net zero (embodied and operational) carbon from day 1 to build in net carbon negative solutions from 2050 onwards. AWS considers that quantum of growth (at 657 per annum to 2036) is deliverable if growth is located in settlements whose catchments have headroom capacity or where investment is planned by AWS to 2030 and can then be proposed in AMP8 and 9 (2020- 2040). AWS supports the allocation of employment land, although until those sites come forward for planning and their water demands and wastewater volumes are known it is not possible to assess the deliverability of employment allocations.

Full text:

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Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

4.11

Representation ID: 13979

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

4.11 and Table 2. AWS has assessed the wastewater recycling centre (WRC) permitted dry weather flow (DWF) capacity and assigned a RAG value in the provided table [see attachment] to those locations based upon the allocations and average build out rates. This now includes consideration of existing planning applications and potential construction build outs for those sites. The RAG table for the WRC/ settlements based on the five-year average (mean) flows at Q80.

Full text:

See attachment for representations.

Attachments:

Object

Regulation 19 - Proposed Draft Local Plan Submission

4.12

Representation ID: 13987

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

On the soundness question, AWS considers that whilst some 1,534 of the allocations are in WRC catchments that would require a pre-occupation condition if those applications came forward before WRC capacity was completed in AMP8 this does not prevent those sites from being delivered. AWS recommends that all allocations have supporting text which advises applicants to engage early with AWS to ensure that AWS investment can where possible be accelerated to support the occupation of new homes. For the 151 dwellings allocated to Husbands Bosworth, Great Easton, Hallaton which have no WRC capacity and no planned investment before 2030, AWS recommends that the Council considers phasing those sites after 2030.

Change suggested by respondent:

AWS recommends that all allocations have supporting text which advises applicants to engage early with AWS to ensure that AWS investment can where possible be accelerated to support the occupation of new homes.

For the 151 dwellings allocated to Husbands Bosworth, Great Easton and Hallaton which have no WRC capacity and no planned investment before 2030, AWS recommends that the Council considers phasing those sites for the last sixteen years of the Plan i.e. after 2030. AWS notes that this would require one site shown in Appendix 5 for delivery commencing in 2029/30 in Husbands Bosworth to be rephased by one or more years to 2030/31 or later to enable additional capacity to be provided by AWS in AMP9 (2030-35).

Full text:

See attachment for representations.

Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

4.17

Representation ID: 13994

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

AWS welcomes that none of the eleven WRCs which have descriptive permits have named allocations in the villages they serve. AWS re-iterates our previous advice and published guidance that windfall sites in these eleven catchments would without developer funded monitoring of flows be unable to support windfall housing sites. AWS recommends this is clearly set out in an addition modification to the supporting text in paragraph 4.17.

Change suggested by respondent:

Windfall sites in the eleven catchments served by WRC with Description Permits would without developer funded monitoring of flows be unable to support windfall housing sites. AWS recommends this is clearly set out in an addition modification to the supporting text in paragraph 4.17.

Full text:

See attachment for representations.

Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

Policy DS02 Development Strategy: Creating Jobs and Diversifying the Economy

Representation ID: 13995

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

AWS supports the employment policy and confirms that developers will be required to fund additional WRC and network capacity for trade effluent flows from the new and expanded businesses.

Full text:

See attachment for representations.

Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

Policy DS03 Development Strategy: Tackling Climate Change and Enhancing the Natural Environment

Representation ID: 13997

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

AWS supports the sustainability hierarchy approach and the reduction in energy use and so GHG from development and the aligned improvements in water efficiency and consequent reductions in wastewater volumes per capita as new buildings and their use become more efficient. Not immediately evident how the selection of the spatial strategy has been informed by reducing the need for new infrastructure through utilising existing capacity. This may require additional supporting text to Policy DS03 showing how the spatial choice is justified and effective from a capital (embedded) carbon position as well as operational carbon.
Parts c. and d. of the policy and specifically the Local Natural Recovery Strategy are supported.

Change suggested by respondent:

Consider additional supporting text to Policy DS03 showing how the spatial choice is justified and effective from a capital (embedded) carbon position as well as operational carbon – such as the transport emissions referenced in paragraph 4.34.

Full text:

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Attachments:

Support

Regulation 19 - Proposed Draft Local Plan Submission

4.38

Representation ID: 14000

Received: 06/05/2025

Respondent: Anglian Water Services Ltd

Representation Summary:

AWS welcomes the consistent referencing of blue infrastructure along with green infrastructure and we consider that this is consistent with national policy.

Full text:

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Attachments:

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